ID: 1983-1.36

TYPE: INTERPRETATION-NHTSA

DATE: 04/00/83 EST

FROM: GREAT WEST CASUALTY CO.

TITLE: GW SAFETY TALK

ATTACHMT: DECEMBER 30, 1988 LETTER FROM JONES TO SPRUNK, OCTOBER 8, 1987 LETTER FROM SPRUNK TO JONES, BROCHURES ON TIRE SIPING, 1978 NSC WINTER TEST REPORT, AUGUST 19, 1986 LETTER FROM KEIL TO SPRUNK, ARTICLE FROM AUGUST 1986 ISSUE OF "SCHOOL BUSINESS AFFAIRS," ARTICLE ENTITLED "SLASHING TIRES FOR SAFETY AND SAVINGS" FROM DECEMBER 1984 "NATIONAL SCHOOL BUS REPORT," MARCH 20, 1985 LETTER FROM GIFFORD TO SPRUNK, AND OCTOBER 15, 1982 LETTER FROM PALMER TO MARCY MANUFACTURING

TEXT: LOSS PREVENTION TOOL: In our mailing to fleets, we will include a brochure or pamphlet regarding Siping of Tires. We do not have any statistics or facts concerning the Siping of Tires. However, we insure several carriers who siping every tire in the fleet and they and their drivers are convinced it is a major safety factor that cannot be ignored on rain, snow, or ice slick highways. These carriers talk in terms of better control, better maneuverability, cooler running tires, better mileage, etc.

SIPING OF TIRES. Some time ago, we wrote a short article about siping of tires which improved traction on wet and icy roads, ran cooler, etc. We were surprised at the calls from carriers who didn't know what siping was. I personally talked to 2 carriers and their drivers report substantial traction improvement on wet and slick roads. One carrier was having some difficulty with unusual wear patterns on the tire. They siped them and it corrected the problem. When the carrier and the driver gives validity to the process, then it is worthy of consideration.

SAF-TEE SIPING CALL YOUR FELLOW TRUCKER AND *Improves Traction on Wet and CHECK FOR YOURSELF Icy Roads (22% National Safety Council) *Increases Tire Life 15% to 20% 1. Palmer Trucking - Jim Palmer, (406) 721-5151 2. Unthum Trucking - Keith Reilly, (515) 448-4707 *Decreases Uneven Wear Patterns 3. Holland Trucking - Dennis Holland, (701) 280-2634 50% - 70% (Tread Flexes More) 4. Apple Lines - Dale Coates, (605) 256-6661

ID: 1983-1.37

TYPE: INTERPRETATION-NHTSA

DATE: 04/05/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyo Tire Corporation

TITLE: FMVSR INTERPRETATION

TEXT:

April 5, 1983 NOA-30

Mr. K. Inoue National Technical Service Manager Toyo Tire Corporation Compton, California 90221

Dear Mr. Inoue:

This responds to your February 16, 1983, letter to Joseph Innes of this agency regarding permissible methods for displaying Uniform Tire Quality Grading (UTQG) information on the sidewall of tires. Your first proposed alternative would delete the treadwear grade number, but not the word "TREADWEAR" itself, from the format established in Option 3 of Figure 1, 49 CFR 575.104. The second proposed alternative would delete both the word "TREADWEAR" and the numerical grade from the format specified in Option 3, Figure 1. Your proposed alternatives would be used only on tires produced in molds manufactured before August 8, 1983.

In the agency's February 7, 1983, notice suspending the treadwear portion of the UTQGS, tires produced in molds manufactured prior to August 8 were required to display UTQG information on tire sidewalls in one of the formats specified in Figure 1 or in Figure 6 of 49 CFR 575.104. Your first proposed alternative is clearly different from each of the permitted formats. The permitted formats require either that the word "TREADWEAR" must appear next to the treadwear grade on the tire, or neither the word nor the numerical grade must appear. Your first alternative could confuse tire purchasers, since the display format could be interpreted as attributing the grade which appears after the word "TRACTION" to both the treadwear and traction performance of the tire. Therefore, your first proposed alternative would not be permitted under 49 CFR 575.104.

Your second proposed alternative is quite similar to one permitted format, Option 3 in Figure 6. The only difference between your second alternative and Option 3 is that the traction information is centered in the format in Option 3, while it is slightly off-center in your alternative. Your second alternative should in no way be misleading to tire purchasers, however. Further, nothing in our regulations specifies precise centering of the traction information.

Any inconsistency between your proposed format and the permitted one is so small that the agency would, as a matter of prosecutorial discretion, make no attempt to enforce the UTQGS format requirement when your second alternative is used.

If you have further questions on this matter, please contact us.

Sincerely,

Frank Berndt Chief Counsel

February 16, 1983

Mr. Joseph Innes Office of Market Incentives National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Innes:

Regarding our telephone conversation to you on February 16, this is the official written question. We would appreciate your prompt reply. We have the following questions regarding the amendment of UTQG regulation:

Can we modify the molding grading information on the sidewall of the tire produced in the mold manufactured before August 7, 1983 from Figure 1 the following way?:

1). If we take off the grading number of the treadwear from Figure 1, (PLEASE SEE EXAMPLE) is it acceptable?

**INSERT**

2). If we take off the letters of TREADWEAR and the grading number of the treadwear from Figure 1. (PLEASE SEE EXAMPLE) is it acceptable?

**INSERT**

In case we change the tread compound of the tire as the grading of treadwear is changeable, we need this kind of modification. According to your purpose of the amendment, we think this modification shall be allowed.

Sincerely yours,

K. Inoue National Technical Service Manager

KI/lg

ID: 1983-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 04/05/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Flyer Industries Limited

TITLE: FMVSS INTERPRETATION

TEXT:

APR 5 1983 NOA-30

W. E. J. Moss, P. Eng. Flyer Industries Limited 64 Hoka Street Box 245 Transcona P.O. Winnipeg, Manitoba Canada R2C 3T4

Dear Mr. Moss:

This responds to your January 27, 1983, letter asking about the application of Standard No. 217, Bus Window Retention and Release, to the front entrance doors of buses. You ask that the window retention test not be applied to your bus, because application of the required amount of force will cause the door to open. You state further that if the door had no glazing, it would not be tested for retention and, therefore, would be acceptable under the standard.

Standard No. 217 states that all glazing that exceeds 8 inches in diameter shall be tested for retention. During that test, neither the glazing nor the surrounding frame shall open in a manner that would allow a 4-inch sphere to pass through the opening. The intent of this requirement is of course to prevent the ejection of occupants in accidents.

The agency does test the front door of buses for compliance with this section if they contain glazing that meets the size requirement. In tests that have been conducted, most front doors have complied. Accordingly, the proper construction of front doors in compliance with the requirement would not appear to be a problem. The agency does not believe that it would be in the interest of safety to exempt front door glazing from the test requirements. Although passengers are required to stand behind the standee line as you note in your letter, they may easily be thrown forward of that line in an accident. The agency considers it important to reduce the possibility of their being thrown from the vehicle if such a situation were to arise.

You are technically correct that an all metal door would not be tested for compliance with this retention provision since it would not contain glazing. However, the agency would not view favorably the installation of doors in buses that open so easily in an accident. Use of such doors might be considered to be a safety-related defect subject to the agency's recall and remedy authority.

Sincerely,

Frank Berndt Chief Counsel

January 27, 1983

Administrator, National Highway Traffic Safety Administration, Attn: Mr. R. Tildon 400 Seventh Street S.W., Washington, D.C. 20590 U.S.A.

Petition

Dear Sir:

I wish a clarification of FMVSS #217 on the front doors of a transit coach. This coach has two piece "slide glide" type doors.

If a solid aluminum door is used and tested to FMVSS 217 the door will deflect enough to permit passage of the 4" ball. In this case the door will pass FMVSS 217, as there is no glazing in the door.

In the case of glazing in the door, "this is necessary to allow the driver visability", the deflection will be the same magnitude as a solid door permitting the passage of a 4" diameter ball. This then does not pass the FMVSS test on this glazing, as the frame is not retained by its surrounding structure, nor can it be.

I ask for an exception for the front door glazing of a transit coach from FMVSS 217. This would not pose a danger as the passengers are asked to stand behind a whiter yellow line on the floor rearward of the front door area.

Yours truly,

W.E.J. Moss, P. Eng Test Engineer

/jc B-286

ID: 1983-1.39

TYPE: INTERPRETATION-NHTSA

DATE: 04/07/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dunlop Tire Company

TITLE: FMVSR INTERPRETATION

TEXT:

APR 7 1983 NOA-30

Mr. Richard H. Attenhofer Technical Manager, O.E Dunlop Tire Company Box 1109 Buffalo, New York 14240

Dear Mr. Attenhofer:

This responds to your recent letter to Mr. Kratzke of my staff, requesting an interpretation of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked if Dunlop could use a print type called OCR-A for the DOT symbol and the tire identification number.

Note 1 to Figure 1 of Part 574 specifies only four different print types which may be used for the DOT symbol and identification number, none of which are OCR-A. However, Note 4 to Figure 1 states that other print type will be permitted if approved by this agency. We have examined the print type shown in the diagram attached to your letter and have no objections to your company printing the required information in OCR-A type.

In the final rule establishing Part 574 (35 FR 17257, November 10, 1970), the agency explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The OCR-A print type shown in the diagram attached to your letter is easily readable and thus satisfies our concerns in that regard. Accordingly, that print type is hereby approved.

Sincerely,

Frank Berndt Chief Counsel

February 10, 1983

Mr. Steven Kratzke Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, D. C. 20590

Dear Mr. Kratzke:

Dunlop Tire and Rubber Corporation wishes to utilize the latest electronic techniques for sorting and inventory control of automobile, motorcycle and truck tires which are subject to Tire Identification and Recordkeeping as defined in CFR 49, Chapter V, Part 574.

We request an interpretation of your office if the style of characters shown on the attached sketch 9522-DS do meet the requirements of Notes 1 or 4 shown in Figure 1 of Part 574.

Dunlop is grateful for your prompt consideration of this matter. Should you have any questions please call me direct at 716/879-8327.

Very truly yours,

DUNLOP TIRE & RUBBER CORPORATION

Richard H. Attenhofer, Technical Manager, O.E.

ID: 1983-1.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: CONSUS INTERNATIONAL, INC

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Robert B. Wessel Consus International, Inc. P.O. Box 594 Port Jefferson Station, NY 11776

Dear Mr. Wessel:

This is in response to your December 1, 1982, letter regarding a warning device you plan to manufacture. The device is powered by 4 AA batteries, and has a light which can stay on continuously or can flash. You have asked whether the device complies with Federal Motor Vehicle Safety Standard 125.

Standard 125 applies to warning devices "without self-contained energy sources." The four batteries in your device which power the light would constitute such a source. Therefore, Standard 125 is inapplicable to your device.

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

Sincerely,

Frank Berndt Chief Counsel

December 1, 1982

National Highway Traffic Safety Administration Rm 5219 U.S. Dept. Of Transportation 400 7th Street S.W. Washington D.C. 20590

To Whom It May Concern;

Please review the enclosed sample and advise complience with your standard 125. The unit is made to work with four "AA" Batteries and has reflective as well as lighted capabilities.

The light can stay on, or in the flasher mode will blink, and is visible at great distances.

Thank you in advance for your early response as we are waiting your acknowledgement before our marketing push.

I remain Very truly yours;

Robert B. Wessel

ID: 1983-1.40

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Andial

TITLE: FMVSS INTERPRETATION

TEXT:

APR 13 1983 NOA-30

Mr. Arnold H. Wagner Andial 3207 S. Shannon Street Santa Ana, California 92704

Dear Mr. Wagner:

This responds to your February 2, 1983, letter asking whether a child seat that you plan to produce must comply with Standard No. 213, Child Restraint Systems. From the description of your child seat, it appears that the answer is yes.

Standard No. 213 states in section 4 that a child restraint system is any device used to restrain, seat, or position children who weigh not more than 50 pounds. It is not necessary that a seat be equipped with its own restraint devices to fall within the ambit of the standard. If a device is designed to seat or position a child within the designated weight range, that device must comply with the requirements.

The instructions that accompanied your letter showed how the seat should be installed for children from three to six years of age and subsequently for children in the age range of six to ten. Certainly children in the three to six age bracket would fall within the weight range (50 pounds or less) designated in the standard. Since this is the case, it appears that your child seat is designed to seat or position children of the size specified in the standard and would therefore be required to comply with the requirements of the standard.

Sincerely, Frank Berndt Chief Counsel February 2, 1983 Mr. Frank Berndt Chief Council US Department of Transportation N.H.T.S.A. 400 Seventh Street, S.W. Washington, D.C. 20590 Re: Approval of child restraint, by means of 3 point type belt system

Dear Mr. Berndt:

Enclosed please find copies of a letter from Arvin/Calspan to us, and a copy of the installation instructions of said restraint.

We understand that the application of FMVSS No. 213 restraint designs does not cover our particular system, and a formal decision is needed in order to get it safety approved.

We would like to ask you to consider our request at your earliest convenience.

Sincerely

Arnold H. Wagner Sec/Tres.

AHW/mgm

January 24, 1983

Mr. Arnold Wagner Andial 3207 S. Shannon Street Santa Ana, CA 92704

Dear Mr. Wagner:

We received your child restraint last week and have examined the restraint and the installation instructions. The design of this restraint (i.e., use of a three-point belt system) is not addressed in the Department of Transportation's Federal Motor Vehicle Safety Standard No. 213 (FMVSS 213).

We have been informed by the Department of Transportation that a formal decision is required with regard to the applicability of FMVSS No. 213 to restraint designs which are not specifically addressed in this safety standard. A request for a formal decision should be sent to:

Mr. Frank Berndt Chief Council U. S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

I would suggest that you include a copy of your installation instructions.

A brochure of Calspan's child restraint testing capabilities is included with this letter. Our recommendation for a sled test program follows:

Sled Test #1 - Two restraints placed side-by-side on the sled (see Photograph #2 in brochure). One restraint will be occupied by a 3- year-old size dummy (15 kg) with the restraint installed as suggested for 9-18 kg children and the other restraint occupied by a 6-year-old size dummy (22 kg) with the restraint installed as suggested for 15-25 kg children. This test would be performed at 30 mph as required in FMVSS 213 Configuration 1.

Sled Test #2 - One restraint occupied by a 3-year-old size dummy with the restraint attached to the seat by means of a lap belt only, tested at 20 mph. This should satisfy the requirements of FMVSS No. 213, Configuration II.

Although FMVSS No. 215 only requires testing with the three-year-old size dummy, we have included a test with the larger six-year-old size dummy since your restraint is designed for use by larger children.

Calspan charges one thousand dollars ($1,000) U. S. funds for each sled test, regardless of the number of dummies used. This price includes high-speed movie films, electronic data, and photographs for each test and analysis and reporting of all relevant data.

I look forward to hearing from you soon. We would like to perform these sled tests in February if this is convenient for you.

Sincerely yours,

Barbara J. Kelleher Staff Associate Transportation Research/Physical Sciences

kd

Enc.

ID: 1983-1.41

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: C. H. Percy, U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT:

APR 18 1983 NOA-30

The Honorable Charles H. Percy United States Senate Washington, D.C. 20510

Dear Senator Percy:

This responds to your letter of March 25, 1983 (Ref. 3084500004) requesting information on behalf of your constituent, Ms. Mary Ella Dockson. Ms. Dockson is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. She believes this is a dangerous practice because it prevents other drivers from seeing inside the vehicles. Following is a discussion of the implications under Federal law of installing these tinting films.

A Federal regulation already exists which, under certain circumstances, precludes the practice referred to by Ms. Dockson. 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. This specification for light transmittance precludes darkly-tinted windows in new automobiles.

The agency has stated in past interpretations that solar films such as the type referred to in Ms. Dockson's 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 tinting 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 solar 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.

The individual States must govern the operational use of vehicles by their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Ms. Dockson may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, Illinois 60204) to find out which States have laws that would preclude owners from placing solar film on their automobile windows.

Please contact Hugh Oates of my staff if you have any further questions (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

Enclosure Constituent's Letter

ID: 1983-1.42

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ichikoh Industries Ltd. -- F. Takata, Manager, Technical Research and Homologation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. F. Takata

This is in response to your letter of March 10, 1983, to Marx Elliot of this agency, In that letter, you requested our view as to whether a mirror label printed by a "screen printing process" would comply with section 5.4.2 of FMVSS 111. The screen printing process involves painting the required warning label on the reverse surface of the mirror in such a way that the warning can be read from the front of the mirror.

Section 5.4.2 of FMVSS 111 provides that certain convex mirrors must have "indelibly etched" on the lower edge of the mirror's reflective surface the warning "Objects in Mirror Are Closer than They Appear." Your screen printing process uses a painting process to place the required lettering on a mirror. Since the process does not involve etching, mirrors having a warning placed on them by that process would not now comply with FMVSS 111.

You should be aware, however, that Toyota Motor Corporation has petitioned this agency to permit processes other than etching to be used to place the FMVSS 111 warning on mirrors. We expect to respond to the Toyota petition in the very near future. Should the agency grant the Toyota petition, it could result in an amendment to the Standard permitting the process described in your letter.

Sincerely, Frank Berndt Chief Counsel

Mr. W. Mark Elliot Rulemaking Program Manager Lighting & Visibility. NHTSA

Re: Interpretation of FMVSS No. 111

Dear Mr. Mark Elliot,

First of all, we thank you very much for your kindly reply on headlamp regulation addressed to our Mr. Aihara. Your informations are very useful for us, thank you again.

We also produce the rear view mirrors for motor vehicle. We would like to ask you the interpretation of FMVSS no. 111, Section 5.4.2.. Section 5.4.2. is defined as follows:

S5.4.2 Each convex mirror shall have indelibly etched on the lower edge of the mirror's reflective surface in letters not less than 3/16 inch or no more than 1/4 inch high, the words "Objects in Mirror Are Closer Than They Appear".

The words "OBJECTS IN MIRROR CLOSER THAN THEY APPEAR" on the sample mirror enclosed this letter was printed by screen printing process as shown in the attached sheets.

Questions: May we understand that marking method of enclosed sample complies with requirements of FMVSS No. 111, Section 5.4.2?

And if your have any comments on enclosed sample, please inform us. We await your early reply.

Very Truly yours.

F. Takata, Manager Technical Research & Homologation Enclosures

ID: 1983-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Truck Body & Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 10, 1983, letter asking whether the requirement for audible alarms at school bus emergency doors applies only to emergency exit doors or to both doors and emergency exit windows.

Paragraph S5.3 of Standard No. 217, Bus Window Retention and Release, states specifically that the alarms shall be installed for emergency exit doors. There is no similar requirements for alarms at emergency window exits. Accordingly, alarm devices need be provided for emergency doors only.

SINCERELY, TRUCK BODY & EQUIPMENT ASSOCIATION

March 10, 1983

Office of Chief Counsel National Highway Traffic Safety Administration Attn: Roger Tilton

Dear Mr. Tilton:

This will confirm our telephone conversation of March 10th regarding FMVSS 217. One of TBEA's members would like a written interpretation of whether or not buses (not school buses) with a GVWR of more than 10,000 pounds require an audible alarm system for emergency exits, in this case push out windows so designated, other than doors.

The confusion is caused by S5.2.1 of FMVSS-217 which states in part -- "by providing side exits and at least one rear exit that conforms to S5.3 through S5.5". S5.3 specifically requires the audible alarm for emergency doors only. The standard clearly and consistantly delinates between emergency doors and emergency exits.

Is it reasonable to assume that on buses (not school) with a GVWR of more than 10,000 pounds that the audible warning system applies only to emergency doors and does not apply to emergency exits?

Your kind assistance in this matter will be appreciated.

James E. Forrester Manager, Engineering Services

ID: 1983-1.44

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 20, 1983

FROM: F. MICHAEL PETLER -- HEAD, ADMINISTRATION, GOVERNMENT RELATIONS DEPARTMENT, SUZUKI

TO: OFFICE OF CHIEF COUNSEL -- NHTSA

TITLE: REQUEST FOR INTERPRETATION FMVSS NO. 210; SEAT BELT ASSEMBLY ANCHORAGES

ATTACHMT: MEMO DATED 5-6-83, TO F. MICHAEL PETLER, FROM FRANK BERNDT, NOA-30

TEXT: We are in urgent need of your confirmation of our interpretation of the seat belt assembly anchorage requirements for the rear seat.

Paragraph S4.1.1 of FMVSS No. 210 states:

"Seat belt anchorages for a Type 2 seat belt assembly shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles, and for each designated seating position for which a Type 2 seat belt assembly is required by @ 571.208 in vehicles other than passenger cars."

In your agency's November 2, 1981 denial of Toyo Kogyo U.S.A.'s petition for rulemaking (46 F.R. 54391-54392) the following statement appears:

"The standard requires all passenger cars, lightweight trucks, and multipurpose passenger vehicles to be equipped with three-point anchorages for Type 2 belts (combination lap and shoulder belts) at each forward facing outboard designated seating position. Two-point anchorages for Type 1 belts (lap belts) are required at all other designated seating positions (center front and all rear positions)."

We interpret this standard to require that only Type 1 seat belt assembly anchorages must be installed for each seating position of a rear seat, such as in the case of a passenger car. We would appreciate a prompt reply as to whether we are correct in our interpretation of this standard.