ID: 14516.ztv

Mr. Larry C. Lavender
Fleetline Products, Inc.
P.O. Box 298
Springfield, TN 37172

Dear Mr. Lavender:

This is in reply to your letter of March 28, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

You state that you have received "verbal" answers to certain questions from the Office of Safety Performance Standards and need a written confirmation of these answers from the Office of Chief Counsel. You wish to supply parts to "heavy duty truck manufacturers" that meet Standard No. 108, and are concerned with sheeting to be applied to the rear fenders, mud flaps or mud flap support brackets.

My initial comment is that we encourage manufacturers to seek written interpretations directly from the Office of Chief Counsel. Only the written interpretations of the Office of Chief Counsel are binding.

My second comment is to note that the conspicuity requirements of Standard No. 108 apply only to heavy trailers and to truck tractors that are 80 or more inches in overall width. Thus, a manufacturer wishing to add conspicuity sheeting to rear fenders, mud flaps or mud flap brackets of a straight truck need not follow Standard No. 108. Nevertheless, in the belief that standardization enhances safety, we encourage voluntary compliance with the conspicuity requirements for straight trucks as well.

The interpretations for which you seek confirmation are:

"The sheeting must be in a pattern of alternating red and white segments. The individual segments must be 300mm long plus or minus 150mm, i.e. from 150mm to 450mm long."

Yes. The specifications stated in paragraph S5.7.1.3(a) and (b) for the side and rear of trailers and truck tractors apply also to rear fenders, and mud flaps and their support brackets.

"There is no requirement for the color pattern to begin or end in either color. The inboard and outboard segments may be either red or white."

You are correct. The text of Standard No. 108 speaks of "alternating white and red color segments" (S5.7.1.3(a)) while Figure 30-1 through Figure 30-4 show red and white segments installed. However, there is no requirement that the color pattern begin or end with either color, or that inboard and outboard segments be red or white.

"There is no requirement for the tape to be completely free of discontinuities. On the brackets which have a 45 degree angle, the tape does not have to be cut in a miter joint."

Paragraph S5.7.1.4(a) specifies that sheeting "need not be applied to discontinuous surfaces" and provides several examples of these. We assume that this is what you mean by your statement. There is no requirement that tape be cut in a miter joint.

"Minor trimming of the tape to conform to the shape of a bracket is acceptable, provided the length measured on the center line of the tape is a minimum of 600mm. On the drawing included with this memorandum one corner of the tape is trimmed. This is acceptable."

Minor trimming of the tape is acceptable, as shown on your drawing. The length measured on the center line of the sheeting may be any length from 600mm to 900mm. (300mm +/- 150mm x 2).

"The drawing included with this memorandum illustrates a proposed bracket satisfying FMVSS 571.108."

The drawing shows an acceptable solution to mounting conspicuity material on a mud flap bracket.

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

Sincerely,
John Womack
Acting Chief Counsel
ref:5/28/97
d:5/28/97

ID: 17341.wkm

Mr. Richard H. Allen
Chief Engineer
Eagle Iron Works
129 Holcomb Avenue
Post Office Box 934
Des Moines, IA 50304-0934

Dear Mr. Allen:

Please pardon the delay in responding to your letter to this office in which you asked whether the processing equipment that your company produces for the aggregate industry is excluded from the antilock brake system (ABS) requirement of Federal Motor Vehicle Safety Standard (Standard) No. 121, Air brake systems. The answer is yes.

You stated that some of the equipment that you manufacture is wheel-mounted for ease of transport from the factory to the customer and by the customer between job sites as required. You explained that the equipment is not load-carrying since the equipment is the load. You stated that the equipment was designed to spend its entire life at mining or quarry sites and would probably spend less than one percent of its life on the road. You enclosed brochures depicting and describing the various lines of equipment that you manufacture, specifically alluding to your wheel-mounted portable Sand Washing-Classifying machine, wheel-mounted portable Sand Washer-Classifier-Dehydrator, and your portable wheel-mounted Log Washers.

Chapter 301 of Title 49, U.S. Code (hereinafter Safety Act) authorizes this agency to establish Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The Safety Act defines "motor vehicle" as:

[A] vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways, but does not include a vehicle operated only on a rail line.

49 U.S.Code 30102(a)(6).

In reviewing the information you provided, including your brochures, it is our opinion that the aggregate equipment that you described and as depicted in your brochures are not motor vehicles within the statutory definition. They are obviously designed to be used primarily off-road and although they are portable and therefore capable of being transported on-road from the factory to the customer and by the customer from one job site to another, their on-road use is only incidental and not the primary purpose for which the equipment was manufactured. Not being motor vehicles, therefore, your wheel-mounted items of equipment, such as your Sand Washing-Classifying machines, Sand Washer-Classifier-Dehydrators, and Log Washers are not required to comply with the Federal motor vehicle safety standards, including Standard No. 121.

Standard No. 121 (copy enclosed), requires trailers, among other vehicles, equipped with air brake systems to be equipped with ABS. Excluded from that requirement, however, is

Any trailer that has an unloaded vehicle weight which is not less than 95 percent of its GVWR.

49 CFR 571.121, paragraph S3(f).

Your information would indicate that the equipment in question would also meet this exclusion since, as mentioned above, the equipment is the load. Accordingly, even if your equipment were considered motor vehicles, they would still be excluded from the ABS requirement under this provision.

I hope this information is helpful to you. Should you have any further questions or need additional information, feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, fax (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:121#VSA
d.6/1/98

ID: 1984-1.46

TYPE: INTERPRETATION-NHTSA

DATE: 05/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: U.S. Postal Service

TITLE: FMVSS INTERPRETATION

TEXT:

May 3, 1984

Mr. Joel S. Premack Research and Development Laboratories U.S. Postal Service Rockville, MD 20852-8101

Dear Mr. Premack:

This responds to your March 7, 1984 letter to Roger Fairchild of this office regarding Federal Motor Vehicle Safety Standard (FMVSS) 111, Rearview Mirrors. In particular, you asked whether the covering of the rear and rear-side windows on Postal Service Vehicles would be consistent with the requirements of FMVSS 111.

FMVSS 111 (copy enclosed) establishes requirements regarding rearview mirror systems on new motor vehicles. New Postal Service vehicles would be required to employ one of three optional mirror systems. The first system is a system permitted for use on passenger cars, and includes an inside review mirror with a specified field of view and a plane, driver's side exterior mirror also having a specified field of view. The second permissible system is also a passenger car system and is identical to the first system, except that the inside mirror need not provide the specified field of view and an additional passenger side plane or convex rearview mirror must be provided to compensate for the more restricted field of view of the inside mirror. The third system has two plane mirrors of 19.5 square inches reflective surface area each, one mounted on each side of the vehicle.

Based on the materials you provided with your letter, it appears that Postal Service DJ-5G Models employ the second system described above. In that case, further reduction of the field of view of the inside rearview mirror would not affect compliance with our standard, since an additional passenger side mirror is provided.

If the proposed covering of the rear windows is to be accomplished as a modification to vehicles already delivered to the Postal Service, these modifications may not be subject to FMVSS 111 at all. Modifications to vehicles must be consistent with safety standards only to the extent those modifications are performed by a vehicle manufacturer, distributor, dealer, or private motor vehicle repair business which knowingly renders inoperative safety equipment installed on the vehicle. See 15 U.S.C. 1397(a)(2)(A). Thus, if the window covering is done by the Postal Service itself, FMVSS requirements are not applicable.

If you have any further questions on this matter, please feel free to contact us.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

March 7, 1984

Mr. Roger Fairchild National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590

Dear Mr. Fairchild:

The Engineering Support Center of the U.S. Postal Service has been requested to consider covering over windows identified as items 1, 2, and 3 in the enclosed figure. A set of mirrors would be installed to minimize the impact on rear and side viewing. He are interested in knowing whether such a retrofit is consistent with the existing vehicle certification.

We would appreciate your review of the proposed change in window area as it pertains to Federal Motor Vehicle Safety Standard 111 and related effectiveness of the rear viewing mirrors. Please contact Mr. Joel Premack on 443-3257 with your assessment of this issue.

Joel S. Premack Mechanical Engineer, Program Engineer Mechanical Design/Development Branch Engineering Support Center 11711 Parklawn Drive Rockville, MD 20852-8101

Enclosure

********INSERT GRAPHIC********

AM General Corporation MODEL KJ-5G

ID: 1982-2.25

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: P. S. Woolley

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 26 1982

Mr. Phillip S. Woolley 10769 63rd Way N. Pinellas Park, FL 33565

Dear Mr. Woolley:

This is in reply to your letter of July 8, 1982, to Mr. Vinson of this office asking what you must do pursuant to Federal regulations as a manufacturer of taillamps for boat trailers.

The Federal motor vehicle safety standard you must consider is Standard No. 108, Lamps, Reflection Devices, and Associated Equipment. (Title 49, Code of Federal Regulations, S571.108) Under its terms, every vehicle taillamp must meet the requirements of SAE Standard J585e Tail lamps (Rear Postion Lamps), September 1977, and the SAE materials referenced in J585e, except that paragraph S4.1.1.12 of Standard No. 108 establishes alternative photometric equipment. The standard does not establish per se a minimum lens area for a taillamp. However, a vehicle manufacturer is required to ensure that when a tail lamp is installed, "the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex," at least 2 square inches in extent, measured at 45 deg. to the longitudinal axis of the vehicle" (paragraph 4, J585e).

As a manufacturer, you are required to certify compliance of each taillamp with all applicable Federal motor vehicle safety standards, which may be by labelling the lamp with the symbol DOT, or by a statement on the lamp or on its shipping container (paragraph S4.7.2, Standard No. 108). You are also required to file an identification statement with the agency (49 CFR Part 566). In the event any taillamp fails to comply with Standard No. 108, or incorporates a safety-related defect, you must notify purchasers and remedy the problem in the manner specified by 49 CFR Part 577, after filing a report with the agency (Part 573).

You may obtain a copy of all Federal requirements by sending a check for $8 to the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 and asking for "Title 49 Code of Federal Regulations - Parts 400 to 999, revised as of October 1, 1981."

For further information on the SAE materials, write "Technical Division, SAE, 400 Commonweath Drive, Warrendale, PA 15096 (or call 412-776-4841). In addition to J585e, you will need copies of J575e Tests for Motor Vehicle Lighting Devices and Components, August 1970; J576d Plastic Materials for Use in Optical Parts Such as Lenses and Reflection of Motor Vehicle Lighting Devices, June 1976; and J578c Color Specification for Electric Signal Lighting Devices, June 1977.

Sincerely,

Frank Berndt Chief Counsel

Phillip S. Woolley 10769 63rd Way N. Pinellas Park, Fl. 33565

July 8, 1982

Mr. Taylor Vinson - F.M.V.S.S. - 108 Legal Counsel National Highway Traffic Safety Assoc. Room 5219 400 7th Street S.W. Washington, DC. 20590

Dear Mr. Vinson:

Our company intends to manufacture tail lights for boat trailers and we need to know in laymans terms exactly what we have to do to comply with the rules and regulations set by the Federal Department of Transportations section 108. Are there any rules regarding square inches of lens surface area?

Thank you very much,

Phillip S. Woolley

P.S. Your name was referred to me by the National Highway Transportation Dept.

PSW/kw

ID: 1983-3.38

TYPE: INTERPRETATION-NHTSA

DATE: 12/21/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Jeff S. Brantner

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of November 9, 1983, to the Urban Mass Transit Administration, which was forwarded to this agency for reply, concerning legal requirements regulating window stickers. The following discussion addresses the Federal requirements applicable to sticker or other films applied to glazing materials in motor vehicles.

The National Highway Traffic Safety Administration has the authority to govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance.

The agency has stated in past interpretations that films such as the type referred to in your letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.

After a new vehicle has been sold to the consumer, he may alter his vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. "Render inoperative" means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $ 1,000 for each violation.

Please contact Stephen Oesch of my staff if you have any further questions (202-426-1834).

SINCERELY,

Arthur E. Teele Jr. Urban Mass Trans. Admin.

November 9, 1983

Dear Mr. Teele.

I have designed an automobile sticker that I feel is very catchy and will hopefully be on the rear windows of a large number of vehicles. I do have a question though, regarding the legal size of a window sticker. My tentative design is three (3) inches high by sixteen (16) inches wide. I feel that the width is not as critical as the heighth as far as a visability restriction is concerned, yet I would like to keep it legal in order to avoid any trouble.

I will appreciate any help that you can give me, since this means a great deal to me. Thank you, in advance, for your time and effort.

Jeff Brantner

ID: 1985-02.35

TYPE: INTERPRETATION-NHTSA

DATE: 05/29/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. R. David Hawkins

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. R. David Hawkins Laboratory Technician Failure Analysis Associates 10899 Kinghyrst, Suite 245 Houston, Texas 77099

Dear Mr. Hawkins:

This responds to your letter asking about Federal Motor Vehicle Safety Standard No. 207, Seating Systems. You asked whether buses are excluded from the requirements of section S4.2, section S4.3, and/or the static testing procedures of section S5. You also asked whether there are any other standards which provide criteria for the testing of seating systems on buses.

Section S2 of Standard No. 207 provides that the standard applies to buses (among other vehicle types). Section S4.2, General performance requirements, provides that "(w)hen tested in accordance with S5., each occupant seat other than a side-facing seat or a passenger seat on a bus, shall withstand" specified forces. Passenger seats on a bus are thus excluded from the requirements of section S4.2. However, the driver's seat on a bus is not excluded from the requirements of that section. The testing procedures of section S5 are only relevant to seats which are subject to the general performance requirements of section S4.2.

Similarly, section S4.5, Restraining device for hinged or folding seats or seat backs, provides that "(e)except for a passenger seat in a bus or a seat having a back that is adjustable only for the comfort of its occupants, a hinged or folding occupant seat or occupant seat back shall" meet specified requirements. Passenger seats on a bus are thus excluded from the requirements of section S4.3. Assuming that a hinged or folding occupant seat or occupant seat back were provided for the driver, it would not be excluded from the requirements of that section unless it had a back that was adjustable only for the comfort of its occupant.

With respect to your last question, Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection, specifies criteria for the testing of school bus passenger seats. That standard is not applicable to buses other than school buses. The agency does not have any other standards which provide criteria for testing seating systems of buses.

Sincerely, Jeffrey R. Miller Chief Counsel Failure Analysis Associates

March 6, 1985 Mr. Steve Wood Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D.C. 20590

Re: Our File No. HS30089

Dear Mr. Wood:

In regard to our recent phone conversation, I am sending this following list of questions pertaining to Motor Vehicle Safety Standard No. 207. This standard deals specifically with seating systems--passenger cars, multipurpose passenger vehicles, trucks, and buses. The purpose and scope of this standard is to "establish requirements for seats, their attachment assemblies, and their installation to minimize the possibility of failure by forces acting on them as a result of vehicle impact".

1. Am I correct in assuming that buses are excluded from: the general performance requirements (S4.2), restraining device for hinged or folding seats or seat backs (S4.3), and also excluded from the static testing procedures outlined in (S5)?

2. If buses are indeed excluded from all of the above, are there any other standards which provide criteria for the testing (visual, static, or dynamic) of seating systems on buses?

Thanks for your attention to this matter.

Sincerely, R. David Hawkins Laboratory Technician RDH:cdk

ID: 1985-03.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/11/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: K. Weight

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. K. Weight 65 E. 200 N. Provo, UT 84601

Thank you for your letter to Secretary Dole concerning black windows in automobiles. Your letter was referred to the National Highway Traffic Safety Administration since we are the agency that issues Federal Motor Vehicle Safety Standards (FMVSS). We have issued FMVSS No. 205, Glazing Materials, which sets performance requirements, including light transmittance requirements, for glazing used in motor vehicles. As explained below, FMVSS No. 205 limits the use of darkly tinted windows.

FMVSS No. 205 requires glazing, both tinted and untinted, in a new passenger car to transmit at least 70 percent of the light that falls on it. To give you an idea of what level of tinting is allowed, please consider the following examples. If a window were completely open, the light transmitted through the opening would be 100 percent; clear windows have about 90 percent light transmittance, while factory-equipped tinted windows in new vehicles have about 80 percent light transmittance.

Minimum visibility levels are necessary to allow the average driver to detect other vehicles, pedestrians, bicyclists and traffic and road signs under all lighting conditions. Were the light transmittance less than 70 percent, such as found in darkly tinted glazing, visibility would be reduced to the extent that it could pose a safety hazard. From your description, I assume that the light transmittance of the "black window" is less than 70 percent. A situation where the light transmittance is below 70 percent may be in violation of FMVSS No. 205.

No manufacturer or dealer is permitted to install tinting material in new vehicles without certifying that the vehicle continues to be in compliance with the light transmittance requirements of the standard. If a dealer, manufacturer, repair business or distributor installs dark tinting material in a used vehicle, then a violation of Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may result. That section provides that none of these persons may knowingly render inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard. Violation of the "render inoperative" provision can result in Federal civil penalties of up to $1,000 for each violation.

Owners of used vehicles may, themselves, alter their vehicles, so long as the vehicle adheres to all State requirements. Under Federal law, the owner may in this manner install dark tinting material regardless of whether the installation adversely affects the light transmittance. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from applying dark tinting material on their vehicles.

I hope this information is helpful to you.

Sincerely,

Jeffrey R. Miller Chief Counsel

5/4/85

Elizabeth Dole - PERSONAL National Highway Traffic Admin. 400 Seventh St. SW Washington. D. C. 20590

Dear Mrs. Dole:

I wrote you 4/26/85 re several safety questions I had.

I am wondering why black windows are allowed on automobiles now? With kidnappings, and failure for a police officer to see into a car, I am thinking these dark windows should be banned.

If I am writing to the wrong dept. please tell me who to write.

Very truly yours,

K. Weight 65 E 200 N Provo, Utah 84601

ID: nht73-2.7

DATE: 08/07/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Sebring Vanguard Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 30, 1973, requesting further information about the relationship of the Federal motor vehicle safety regulations to the Vanguard electric vehicle.

You ask the following questions:

"1. Would prior commitments made before May 16, 1973, be sufficient for a temporary exemption?"

Previously-existing commitments for parts that do not conform to systems covered by Federal motor vehicle safety standards may be presented to support the argument that compliance as of January 1, 1974, would cause substantial economic hardship. No temporary exemption has ever been requested on this basis alone, however, and whether an exemption would be granted solely on this basis would depend upon other facts in the case.

"2. Can VANGUARD be classified as a multipurpose passenger vehicle and what relief would that give us from adhering to federal safety standards?"

As you know, a "multipurpose passenger vehicle" (MPV) is defined in part as a vehicle "with special features for occasional off-road operation." Intent for incidental off-road use is insufficient to qualify a passenger car as an MPV. The manufacturer makes the initial determination whether a vehicle is a passenger car or whether it is a MPV, incorporating "special features" for occasional off-road operation not normally found on a passenger car. If he asks our views, we will provide them. If he does not, we are not precluded from questioning his vehicle categorization at a later date if it appears erroneous to us. The Vanguard appears to be a passenger car, but we would be willing to consider the matter further if you think it possesses unique off-road features.

"3. How can we incorporate safety improvements in our vehicles prior to January 1, 1974, that may put us over the weight limit without violating law?"

When you have completed a definitive review of your compliance problem areas you may apply for such exemptions as appear necessary. If safety improvements result in a vehicle weight that exceeds 1,000 pounds, you may legally market a vehicle if it has been exempted before January 1, 1974.

We appreciate your keeping us informed of your program with the Vanguard.

Sincerely,

SEBRING VANGUARD INC.

July 30, 1973

Lawrence R. Schneider -- Chief Counsel, U.S. Department of Transportation, NHTSA

Dear Mr. Schneider:

This is in reply to your letter of May 31, 1973, which indicated that you are willing to meet with us to explore various alternatives to federal safety regulations in connection with the VANGUARD Electric Sport Coupe. (49 CFR Part 571) We are pleased of the position you have taken.

We wish to bring you up to date on recent developments, VANGUARD VEHICLES, INC. of Kingston, N. Y. has purchased the right, title and interest in the manufacturing of these vehicles from CLUB CAR, INC. of Augusta, Georgia.

A new corporation; SEBRING-VANGUARD, INC. of Sebring, Florida has completed licensing negotiations with the New York company to manufacture VANGUARDS. A proposed production schedule is enclosed.

Certain component lead-time commitments were entered into prior to the May 16th ruling removing the 1000 pound exemption. In order to facilitate actual marketing of a low-emission vehicle in conjunction with an active program of research and development, we are considering petitioning for a temporary exemption under Part 555 to avoid the economic hardship of non-utilization of the above commitments.

As far as we can determine this is the first company organized solely for the purpose of mass-producing electric on-the-road vehicles since the early 1900's. Competent and experienced personnel are in Sebring now operating, as a team. Companies such as Gould, Prestolite, ESB, Bendix and GE have sent engineers to assist our start-up. A sophisticated electric vehicle laboratory is in operation under the direction of Ronald Gremban, who helped build, and drove Cal Tech's successful entry in "The Great Electric Car Race" between that institution and M.I.T. a few years ago. Our Mechanical Engineering department is headed by Robert Rice of Detroit, who built many of Electric Fuel Propulsion's early experimental vehicles. Our company is well financed and two members of our board are currently chairman of New York Stock Exchange listed firms.

The May issue of Reader's Digest (reprint enclosed) had an article entitled "Is The Electric Car Coming Back?" VANGUARD was featured. The current issue of True magazine has a large photo of VANGUARD on Page 18. As a result of articles such as the above, we have received over 1000 phone calls and over 5000 written requests for more information from interested citizens and companies here and abroad. Negotiations for export to Germany, Japan and Bermuda are underway.

Our staff has made a review of standard numbers 101 through 121. Preliminary opinion indicates standard 103, and part of 104, 105 and 114 may be our only problem areas. Further study will determine if we specifically request your guidance on aspects of the above mentioned standards that could hinder our ability to produce and market.

We request that NHTSA carefully consider any variance from standards which we ask because of inherent limitations of our basic energy source; the lead-acid battery. Any added excess weight seriously diminshes effective utilization of the electricity stored in our vehicles. We believe NHTSA is aware of this. It is our opinion that the most abundant and inexpensive source of energy remaining for personal transportation is the combination of lead and sulphuric acid. Its vast potential to this end should be judiciously used.

One other area we wish to explore is VANGUARD'S classification. The following are various purposes for which VANGUARD is currently used:

Mr. and Mrs. S. E. Cronquist of the Swedish Embassy of Washington, D. C. used their VANGUARD as a family second car.

The Winged-Foot Country Club of Westchester County, New York is using a VANGUARD with specially equipped tires for transportation for the head grounds keeper's transportation around its huge fairways and other acreage.

The City of Ft. Lauderdale, Florida recently purchased a VANGUARD for experimental use by City Meter Maids.

Mr. Sam Kelly of Dearing, Georgia purchased a VANGUARD in April of this year. Mr. Kelly is partially paralyzed on the left side of his body and could not operate a conventional auto. The VANGUARD is currently making his life richer.

Mr. John Paynter of Vineyard Haven on Martha's Vineyard in Mass. uses his VANGUARD to deliver parts from his marina to boat owners and occasionally tows light weight boats from dock to dock.

The U.S. Dept. of Commerce has used a VANGUARD at the National Weather Observatory in Sterling, Virginia, for over six months to gather data from the various buildings at the sight. They have recently submitted a bid for two more vehicles.

Rockland Power and Light purchased two VANGUARDS. One for carrying a plant manager around the plant site which enables him to get into areas conventional cars could not, including off-the-road critical areas for occasional surveillance. The other vehicle is being used for multi-purposes including electric meter reading.

Ieland F. Bunch, Sr., of Huntington, W. Va. uses his VANGUARD to show clients various real estate parcels.

A businessman in New Martinsville, W. Va. has a 25 year old son with a hearing impediment. The boy refused to drive a conventional car because of this. He now drives a VANGUARD and his father has written us a thank you letter indicating his son has "come out of his shell".

We have been contacted for further information for potential usage is such diverse activities as Zoo oatrol, pizza deliveries, airport usages and a host of other purposes both on-the-road and off-the-road.

The above leads us to believe that use of our vehicle is so divergent and difficult to categorize that it could indeed be considered a "multi-purpose" vehicle. If this should be the case, Mr. Schneider, who determines if it is so and what is the procedure to classify VANGUARD as "multi-purpose"?

There is one final point we wish to discuss. We are anxious to make our vehicle as safe as possible. Current law may preclude this in that certain safety features we may be able to add prior to the January 1, 1974, deadline may put us slightly over the 1000 pound weight limit. Severe economic hardship could occur if we can't deliver cars prior to January 1, yet under existing law we would be in violation if we don't meet all safety standards and our weight is over 1000 pounds. We would sincerely appreciate any comments you could make concerning this problem.

In summary we would like to know:

1. Would prior commitment made before May 16, 1973 be sufficient for a temporary exemption?

2. Can VANGUARD be classified as a multi-purpose vehicle and what relief would that give us from adhering to federal safety standards?

3. How can we incorporate safety improvements in our vehicle prior to January 1, 1974 that may put us over the weight limit without violating law?

May we hear from you at your earliest convenience?

Sincerely yours,

Robert G. Beaumont -- President

Enclosures

CC: James E. Wilson; Senator James L. Buckley; Senator Jacob Javits

(registered) Vanguard electric car

SPECIFICATIONS for the VANGUARD SPORT COUPE

LENGTH: 96" WIDTH: 45 1/2" WHEEL-BASE: 65" WEIGHT: 980 lbs. CONTROLLER: Vanguard variable voltage speed control. TRANSMISSION: Double reduction gear drive. SUSPENSION: leaf springs; Front & Rear. BODY: Triple-thick fiberglass (rust and corrosion proof). FRAME: Extruded aluminum I-beams (rust and corrosion proof). BRAKES: Hydraulic on both rear wheels plus emergency. SPEED: Maximum and cruising 28 mph. RANGE: 40-60 miles with infinite stops/starts depending on temperature and terrain. ACCELERATION: 0-10, 2.1 secs. -0-15, 4.5 secs. 0-25, 11.6 sec. STANDARD EQUIPMENT: Signal lites, brake lites, stop lites, windshield wiper, headlites, parking lites, emergency flashers, side view mirror, rear view mirror, license plate lite, horn, house current battery charger, AS-1 laminated safety glass windshield, fuel gauge, amp-draw gauge, six 6 volt 106 minute batteries. Available body colors: red, blue, yellow, turquoise & cinnamon.

OPTIONAL EQUIPMENT: Two-tone paint (white top), Wheel covers (set of 4), Heater (catalytic), Defroster (electric), Radio and antenna (transistor).

See at: POWR STOP(trademark)

330 South Nevada Colorado Springs, Colorado

Phone: (303) 471-POWR SEBRING Vanguard INC.

July 20, 1973

Charles Zegers -- Electric Vehicle Council

Dear Mr. Zegers:

Bob Beaumont handed me the enclosed Electric Auto Association Newsletter and requested that I write to you for some assistance from your office.

Although you may already have read the newsletter, we do want to bring attention to the circled paragraph regarding cancellation of three show dates. As the article reads, P.S. & F., a Co-sponsor of three shows high-lighting electric cars, dropped out of the program because it felt that the electric vehicle in some way conflicted with the energy crisis.

We would appreciate anything you can do to change this decision or at least clear up what appears to be a serious misunderstanding on the part of P.G.&E and the consumer. In view of the nature of the electric vehicle, popular use of this means of transportation would actually help alleviate the energy crisis. We have seen estimates, confirmed by experts, that it takes less than one gallon of low-grade fossil fuel to generate the electricity necessary to charge the batteries of a VANGUARD Electric Sport Coupe to propel it forty to sixty miles. This figure compares to as many as six or seven gallons of refined fuel to propel a conventional automobile the same distance. However, this figure assumes that liquid fossil fuels are being used to generate the electricity; if all or part of the energy comes from hydroelectric generators or nuclear reactors which do not pollute, the energy demand on our resources is even less. Furthermore, there is no energy crisis from the burning of coal or shale since it is estimated that that source of energy could accomodate us for another one or two thousand years. All of this means that more electric vehicles equals fewer conventional automobiles. Hence, the demand for highly-refined fossil fuel slows down and assures us a longer lasting supply of that particular energy resource.

Another point to convey to the decision-makers at P.G. & E. and consumers is that most electric vehicles are charged during the nights and early morning hours when demand for energy is little. This fact is significant in several ways. With minimal demand for electricity during part of the twenty-four hour day, the power generating facilities are obliged to slow down to a virtual crawl and then work back to a high output capacity when the demand reaches its peak. In the same way that an automobile uses more gasoline in start-stop traffic, so also does a generating power plant run inefficiently. A wide use of electric vehicles would obviously save the power plants and consumer money and natural resources because this start-up slow-down pattern would be minimized.

To reiterate, generating equipment, which represents a huge capital outlay for the utility company and hence a considerable chunk of the consumers electric bill would be used more steadily and efficiently if electric vehicles were charged at night. Continuing the analogy of the automobile, in the same way that a Chevrolet registers better gas-milage in highway driving, so also does a generator get better fuel-power if it is run at a constant rate over a twenty-four hour period, and while the efficiency improves, the utility revenues increase, thus permitting a substantial cut-back in utility rates and an additional savings to the consumer.

With these points in mind, F.G.&.E. might raise another campaign for the electric vehicle. The consumer should also understand these cost comparisons. With the help of your office, we can accomplish this goal.

Sincerely yours,

Robert M. Stone II -- Assistant to the President

CC: Director of Public Relations -- Pacific Gas and Electric; Morley G. Molden -- American Electric Power Corp.

Electric Auto Association news Letter

VOL. IV No. 4

CANCELLATION OF THREE SHOW DATES

We regret to announce that the co-sponsor, PG&E, felt that they should not be urging a greater use of electric power during this time when there is a serious potential power shortage. These displays were to have been during three days each month during July, August and September.

It is hoped that each chapter will be able to utilize this time to organize a local display in shopping centers, or county fairs. Try to get adequate publicity to tell the public of available alternatives for personal transportation while there is the gasoline shortage.

Here is a good chance for electric car enthusiasts to encourage others to join us and to think about building, showing, and using electric cars.

A Reader's Digest

Reprint

Condensed from Discovery Harland Manchester

Is the Electric Car Coming Back?

Clean and quiet, but too poky for the highway, the electrics may yet catch on for short-haul, stop-and-go work in the world's pollution-choked cities

Vanguard electric

Prototype Battronic delivery van

At Kingston, N.Y., I recently poked around the streets in a snappy little automotive midget that had just room enough for two people. It had a top speed of about 28 miles per hour, no carburetor or radiator, and it gave off no exhaust and was almost silent. The car was a Vanguard electric, with which its producer hopes to invade the suburban second-car market.

A few days later, at Boyertown, Pa., I rode in another battery- powered vehicle a prototype of a fleet of 100 to be market-tested as delivery vans.

On a Miami Beach shopping mall, where gas-belching cars are banned, I paid a dime for a ride in an electric surrey with a fringe on top. In a Tampa retirement colony, I borrowed a battery-powered buggy to visit friends. And throughout the country, I've seen electric-powered golf carts used for such non-sporting purposes as delivering papers, transporting, VIPs at airports, and ferrying major-league baseball pitchers to the dugout.

Every now and then someone asks, "Is the electric car coming back?" The answer seems to be: "It's already here." The poky-paced electric doesn't belong on superhighways, but many short-trip drivers who like economy and clean air are finding the relaxing and pleasant vehicle to be just what the doctor ordered.

The Vanguard electric looks a little like a jeep in a ten-gallon hat. It has a body of colored fiber glass, weighs about 980 pounds, and its makers promise a range, between battery charges, of 40 to 60 miles, depending on temperature and terrain. Its charger can be plugged into any household circuit at home or on the road. Recharging its lead-acid batteries takes five to seven hours and costs about 21 cents. The Vanguard's developer, 40-year-old Robert G. Beaumont, used to run an automobile agency. Five years ago, he caught the electric bug, teamed up with a Georgia manufacturer of golf carts and is now turning out the Vanguards at a price of $ 1986.

Beaumont's buggy is likely to have plenty of competition. Thirty companies, including Ford, General Motors, Westinghouse and General Electric, are reported to have short-range, low-speed electric vehicles either in the prototype or limited production stage. A 1972 survey by the Electric Vehicle Council indicated that 55 million Americans would be interested in buying such a vehicle if it were available for under $ 2000. Curiously, the 18-to-29-year-olds showed the greatest interest of any age group.

This surge of interest in electric vehicles comes at a time when the internal combustion engine used in most of today's cars faces a Washington ultimatum to cut down on emissions. Many experts frankly despair of cleaning up the old "I.C.," and scientists and engineers are studying substitutes. The Wankel, * the gas turbine, the steam engine, the stratified-charge engine, the electric and others have their advocates. But none of them is without serious drawbacks. Meanwhile, every day 12,000 additional cars join the polluting procession on our nation's roads.

* See "Watch Out for the Winkel!" The Reader's Digest, January '72.

No magic wand will solve the problem, but there is some hope for a piecemeal approach. Exhaust pollution is by no means geographically uniform. Walk through the commercial streets of any city when trucks are making deliveries and you will inhale exhaust fumes at their worst. At low speeds and when idling, internal combustion engines pour out far more gaseous garbage than they do at high speeds on the open road. Thus a serious auto pollution problem is caused by the millions of short-trip urban vehicles -- delivery vans, buses, mail trucks, refuse trucks, taxis -- that travel less than 100 miles a day at average speeds of less than 30 m.p.h. Why should these city-confined vehicles have the capability, never used by most of them, of barging hundreds of miles non-stop over superhigh-ways at 75 miles an hour?

All cars and all trucks need not be alike. The Battronic Truck Corp. of Boyerton, Pa., is now building 100 electric work vehicles adaptable for either passengers or cargo. The program is sponsored by the Electric Vehicle Council, and 57 cooperating utility companies will buy and test the vehicles under various conditions to obtain operating data. The Post Office, the government, the bread man, the dry cleaner, the parcel-delivery company, the TV-repair man are considered prime candidates for this work horse. Gasoline vehicles on such runs spend up to 85 percent of their time idling. Electric cars do not idle; when you take your foot off the pedal, the power cuts off.

Depending on speed, the new trucks will run from 30 to 68 miles on one battery charge. Actually, however, their range is unlimited because of an ingenious, self-contained, multi-battery pack that slides out of the truck-bed like a bureau drawer. A man with a special carrier can put in a fresh, fully charged pack in five minutes.

Such battery-powered vans are already in regular service in Great Britain, where about 60,000 are registered. A London dairy firm which used hundreds of horse-drawn carts before World War II now operates a fleet of about 4000 specially designed electrics in the Greater London area. Some of the trucks have been in service for 25 years, and are said by the firm to surpass gasoline-fed trucks in low maintenance costs and reliability. And, according to customers who appreciate their early-morning quietness, they "travel on stocking feet."

On the Continent, about 10,000 electric cars are on the road, most of them delivery vans. A prominent German utility firm, RWE, is sponsoring the development of electric vehicles for use in congested urban areas. The goal: for 10 to 20 percent of all new vehicles in Germany to be electric by 1980. Volkswagen, the first big automobile firm to build modern electrics, is supplying part of the trial fleet. In Japan, too, where urban air pollution is probably the world's worst, a program to build electric cars for various uses is under way, sponsored by the government.

The electric car may seem like a radical innovation; actually, it was in use before the internal combustion engine. A primitive battery-driven car appeared in England in 1837; improved electrics were in use in Boston and Des Moines in the late 19th century; and by 1899 several hundred electric taxicabs were operating in New York City. Before World War I, "bird-cage" electric carriages piloted by elegant ladies were a familiar sight in many American towns. More than 100 manufacturers of that era sold a total of some 10,000 electrics a year. As late as the 1930s, many battery-driven panel delivery trucks were in use in American cities. But the range of all these electrics was short, their speed low, their batteries heavy, and they could not compete with the burgeoning gasoline engine.

Batteries that limit speed and range remain the bugaboos of today's electric vehicles. Engineers throughout the world are working on substitutes for today's lead-acid variety, but nothing satisfactory has yet been found. A few years ago, I rode in a car equipped with silver-zinc batteries. It had fast acceleration and cruised at 60 miles an hour. But the silver in its batteries cost $ 20,000. (The electric cars used by the astronauts on the moon also had silver-zinc batteries -- and cost more than $ 12 million apiece, including research and development.) If a superior battery of reasonable cost can be developed, the electric vehicle may indeed become a highway car. Meanwhile, as pollution's fetid miasma spreads in widening circles, some 20 million short-trip vehicles in cities and suburbs could be replaced by the kinds of electric cars now available.

ID: aiam4477

"Dear Mr. Mikoll: This responds to your recent request for confirmatio of your understanding that school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less would comply with the existing requirements of the safety standards if those buses were equipped with a new occupant protection device your company is considering producing. As explained below, this device could not be installed in small school buses as a substitute for safety belts at those seating positions. Assuming those seating positions are equipped with safety belts, the seating positions could also be equipped with this device if the addition of the device does not prevent the safety belts from complying with the requirements of the safety standards. The new device you are considering producing is a 'safety bar.' This bar consists, in part, of two curved metal poles in planes that are parallel to the longitudinal centerline of the bus. These curved poles are joined by three cross members that are parallel to the seat and are covered with padding. The padded surface is angled at the top slightly back from the vertical. The curved metal poles are attached to the outside of the seat in front of the seat whose occupants will be protected by the 'safety bar,' so that the padded surface extends over the entire width of the seat whose occupants it is designed to protect. When the seat whose occupants are to be protected by this 'safety bar' is unoccupied, the padded surface rests approximately on the latitudinal centerline of the seat. When an occupant wishes to be seated, he or she must lift the 'safety bar' and then sit down. The 'safety bar' will then rest on the occupant's thighs. Additionally, a special strap that resembles a very long seat belt assembly must be fastened around the safety bar to hold it in position in the event of a crash. The crash protection requirements for school buses with a GVWR of 10,000 pounds or less are set forth in S5(b) of Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222). That section provides that these school buses must be capable of meeting the requirements of Standard No. 208, Occupant Crash Protection (49 CFR /571.208) as it applies to multipurpose passenger vehicles, at all seating positions other than the driver's seat. The requirements of Standard No. 208 that apply to multipurpose passenger vehicles with a GVWR of 10,000 pounds or less are set forth in section S4.2 of Standard No. 208. That section specifies that multipurpose passenger vehicles with a GVWR of 10,000 pounds or less shall meet the requirements specified for passenger cars in either S4.1.2.1, S4.1.2.2, or S4.1.2.3 of Standard No. 208. Each of these three subsections of S4.1.2 requires each rear designated seating position to be equipped with a safety belt. S4.1.2 gives manufacturers the option of substituting a protection system 'that requires no action by vehicle occupants' for a safety belt at any or all rear designated seating positions. Your proposed 'safety bar' requires two specific actions by vehicle occupants, i.e., lifting the bar so that the seat can be occupied and buckling the strap to hold the bar in place. Therefore, the 'safety bar' could not be considered a protection system that 'requires no action by vehicle occupants,' for the purposes of S4.1.2 of Standard No. 208. Accordingly, each rear designated seating position in small school buses equipped with this 'safety bar' must also be equipped with safety belts. Assuming that these seating positions were equipped with safety belts, the installation of 'safety bars' in small school buses would be a voluntary action on the part of the school bus manufacturer. NHTSA has said in several prior interpretation letters that the systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided that the additional components or systems do not destroy the ability of required systems (the safety belts in this case) to comply with the Federal safety standards. If this is the case, the 'safety bars' could be provided as a supplement to safety belts on small school buses. To install these 'safety bars' in any new school bus, the manufacturer would have to certify that a bus with the 'safety bars' installed complied with the impact zone requirements set forth in S5.3 of Standard No. 222. Thus, if any part of the 'safety bar' was within the head protection zone or leg protection zone, the 'safety bar' would have to be certified as complying with the applicable requirements of S5.3. Additionally, the manufacturer would have to certify that the school buses with these 'safety bars' installed complied with Standard No. 217, Bus Window Retention and Release (49 CFR /571.217). Standard No. 217 requires school buses to be equipped with emergency exits of a minimum size. This means the 'safety bars' could not obstruct emergency exits located adjacent to seats. If you decide to manufacture these 'safety bars,' your company will be a manufacturer of motor vehicle equipment within the meaning of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.). As such, you will have several responsibilities, including the responsibility specified in sections 151-159 of the Safety Act (15 U.S.C. 1411-1419) to conduct a notification and remedy campaign if your company or the agency determines either that the safety bar contains a defect related to motor vehicle safety or that it does not comply with an applicable safety standard. A copy of an information sheet is enclosed, which describes briefly this and other statutory and regulatory responsibilities of manufacturers and explains how to obtain copies of our regulations. Please let me know if you have any further questions or need additional information. Sincerely, Erika Z. Jones Chief Counsel Enclosure";

ID: aiam1943

Dear Commander Heath: This is a further reply to your letter dated January 21, 1975, askin several questions regarding Standard No. 205, Glazing Materials.' We have attempted to incorporate the substance of your questions in our various answers.; 1. *Prime Glazing Material Manufacturer.* A company that buys and the bends or otherwise forms flat plastic glazing material into a motorcycle windshield is *not* a prime glazing material manufacturer, nor is a company which blows or stretches flat plastic glazing material that is purchased from another company. Prime glazing material manufacturers are only those who fabricate, laminate, or temper the glazing material. In neither of the examples you pose is the material fabricated, laminated, or tempered by the company in question.; 2. *Marking Requirements.* In the amendment to Standard No. 20 published November 11, 1972, (37 FR 24035), it was our intention to limit the use of the DOT symbol and manufacturer's code number to the prime glazing material manufacturer. Persons who cut glazing fabricated by others should not under Standard No. 205 utilize the prime manufacturer's code number or the DOT symbol. Our purpose in structuring the marking requirements this way was to enable us to determine, for purposes of attributing responsibility for conformity, which glazing in a motor vehicle had been manufactured by the prime manufacturer specifically for use in that vehicle, and which glazing had been cut, shaped, or otherwise altered before installation.; >>>(a) You are correct in your interpretation that the DOT symbol an the code number are applied by a prime glazing material manufacturer in addition to the manufacturer's trademark. It was our expectation that the prime manufacturer would furnish his customers with a heat stamp of the markings required by Section 6 of ANS Z26, without the DOT symbol and code number, by which the manufacturer cutting or otherwise shaping the material would mark those pieces he cut or shaped.; (b) Glazing produced by a prime glazing material manufacturer that i not designed for use in a specific vehicle should not contain the DOT symbol or the manufacturer's code number.; (c) The NHTSA has assigned numbers only to prime glazing materia manufacturers. We have not inquired, however, whether the company is in fact producing glazing materials for use in specific vehicle applications.; (d) As stated previously, a company which does not manufacture it glazing but which cuts glazing from larger pieces purchased from the producer of the material should not be using the prime manufacturer's code number or the DOT symbol.; (e) You are correct in your conclusion that the marking requirements o the standard do not apply to dealers. However any person (including a dealer) who sells glazing (separately or in a new vehicle) which is improperly marked may be violating Section 108 of the National Traffic and Motor Vehicle Safety Act.<<<; 3. *General Requirements.* >>>(a) Standard No. 205 does presently prohibit dealers from using th prime glazing material manufacturer's code number. If you are aware of instances where this requirement is not being followed, please forward to us the particulars of the cases in question and we will take appropriate action.; (b) Manufacturers who purchase glazing in large sheets and then cut i to fit window frames are not prime manufacturers and may not use the DOT symbol or manufacturer's code number. You are therefore not correct in your statement that a manufacturer of a window assembly may use the prime manufacturer's number even when the window manufactured is for a special application.; (c) The model number of glazing used in motorcycle windshields shoul be that which is assigned to it by the prime glazing material manufacturer in the glazing's original thickness. ANS Z26 calls for testing plastic glazing materials in substantially flat specimens, and not in molded specimens. However, the Federal standard does not require testing. Manufacturers are required only to use due care in the manufacture of their products. A person reforming' the plastic does not thereby become a prime glazing material manufacturer.; (d) The markings which should appear on plastic bubbles on minivan should be those of the prime manufacturer (not the DOT symbol or code number) of the glazing material and not those of the person who reshapes the glazing.; (e) A material marked AS4 that was used as a motorcycle windshiel would technically fail to conform to the standard as the standard does not provide for the use of AS4 materials in motorcycle windshields. However, if the material also conformed to the requirements of AS6 (which is permitted to be used in motorcycle windshields), the nonconformity would not be considered significant.; (f) Our basic approach has been that the standard applies to th vehicle locations specified in ANS Z26, and to any glazing (glass or plastics) used in those locations. However, opaque plastic materials which are clearly structural materials do not fall within the ambit of Standard No. 205.; (g) Standard No. 205 presently limits the use of plastic glazin materials in buses to readily removable windows, which include push-out windows. Plastic materials may not be used in buses in fixed quarter panels or sliding windows that are not readily removable.; We believe our reasons to be valid for limiting the use of the DO symbol and manufacturer's code number to glazing manufactured by prime manufacturers for use in a specific vehicle location. However, we would certainly be willing to consider steps you might suggest to facilitate State inspections that are consistent with the purposes of the labeling requirements presently in effect. Such a suggestion should be in the form of a petition to amend Standard No. 205 and should be specific.; Sincerely, James C. Schultz, Chief Counsel