ID: aiam1365

Dear Mr. Jacobs: This is in reply to your letter of November 21, 1973 to 'U.S. Bureau o Safety' expressing your view that 'the automobile industry should ... have some type of clutch to reverse action when the closing motion of the (power) window meets any resistance.'; I enclose a copy of Federal Motor Vehicle Safety Standard No. 11 *Power-operated Window Systems* which has applied to all passenger cars and multipurpose passenger vehicles with power windows manufactured since February 1, 1971. The objective of the standard is to minimize the likelihood of injury or death occurring when a person is caught between a closing window and its frame, channel, or seat. The NHTSA determined that the most cost-effective way to accomplish this objective was by prohibiting operation of power windows when the ignition key is either in the ignition 'off' position or removed. As you will see from the enclosure, consideration was given to mechanisms that would reverse the direction of the window.; We appreciate your interest in motor vehicle safety. Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1762

Dear Mr. Gobeille::#Please forgive the delay in responding to you letter of November 19, 1974, which requested an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *brake Hoses*, as applied to short lengths of vacuum brake hose.#To fit the information required by S9.1 of the standard on short lengths of hose, you have suggested a labeling format consisting of the required information presented in two lines,#>>>'each in block capital letters and numerals at least one eighth inch high, placed adjacent to one another and separated by the minimum space necessary to assure clarity. The label would occupy no more than three eighths of an inch on a hose approximately two inches in circumference (5/8 inch OD)'.<<<#Because the two lines would be close enough to prevent confusion with any optional labeling which might appear on the opposite side of the hose, it appears that the format you have described complies with the requirements of S9.1 of Standard No. 106-74. #Yours truly,Richard B. Dyson,Acting Chief Counsel;

ID: aiam1484

Dear Mr. Kato:#This is in reply to your letter of April 23, 1974 asking for an interpretation of Standard No. 101, as proposed in the *Federal Register* on September 27, 1973. You reference that portion of Paragraph S4.3.3 which states 'If illumination of controls and displays not listed in Paragraph S4.1 is provided, its intensity shall be variable in a manner that complies with this paragraph'.#The basic requirement of S4.3.3 is that 'A control shall be provided to adjust the intensity of control and display illumination. . . .' We interpret the basic requirement as applying to *all* control and display illumination, not just illumination of the minimum number of controls and displays specified in Tables I and II. Thus if the manufacturer chooses to provide illumination for *any* control or display, even those not related to safety such as the radio or clock, its intensity shall be variable in accordance with Paragraph S4.3.3.#Yours truly, Richard B. Dyson, Assistant Chief Counsel;

ID: aiam5321

Dear Mr. Stewart: This responds to your letter of March 17, 1994 regarding a final rule published November 2, 1992 (57 FR 49413) amending Standard No. 217, Bus Emergency Exits and Window Retention and Release. You requested clarification of the width requirement in S5.5.3(c) for retroreflective tape. You are correct that there was a discrepancy concerning the size of the tape caused by the metric conversion in the final rule. Enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, we will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape. I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure;

ID: aiam3507

Dear Mr. Yokoi: The answers to the questions in your letter of January 20, 1982, ar 'yes' to both questions.; >>>1. The 'adjacent layers' referenced in Federal Motor Vehicle Safet Standard (FMVSS) No. 106, paragraph S7.3.7, are (a) the inner tube and braided layer and (b) the braided layer and outer tube.<<<; >>>2. The adhesion requirements are met if both the tensile strength measured between (a) the inner tube and braided layer and (b) that between the braided layer and the outer cover are equal to or greater than 8lbs/inch as determined using the FMVSS No. 106 procedure. It should be noted that the 8lbs/inch value is an absolute minimum value as indicated in paragraph S8.6.4(a) of the standard.<<<; A copy of FMVSS No. 106 is included for your information. Sincerely, Vernon G. Bloom, Safety Standards Engineer

ID: aiam2398

Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements os S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam5307

"Dear Mr. Haywood: This responds to your letter of December 21, 1993 requesting information about seating requirements for emergency response units you are designing to respond to chemical spills. The response units are tractor trailer combinations which can be driven in and out of the cargo bay of C-130 Hercules aircraft which are used to transport the units to the site. You further describe the response units as follows: Our response units are designed to transport all six (6) of our response team members, for over the highway transportation three (3) of our team members will ride in the tractor and the remaining three (3) will ride in the trailer. During air transportation all six (6) team members will ride in the trailer. By providing seating with lap and shoulder restraints in the response unit for both ground and air transportation we eliminate the need for special crew cabins for air transportation, and extra vehicles for ground transportation. This conserves the limited space available on the C-130 allowing us to carry all the equipment needed to respond effectively to large scale chemical releases. You requested information on the regulation of the seating in the response units. You have already contacted several Department of Transportation agencies, including the Federal Aviation Administration. I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act), to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. The Safety Act defines the term 'motor vehicle' as follows: 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. If a vehicle is a 'motor vehicle' under the definition, then the vehicle must comply will all applicable safety standards, including those related to seating and occupant restraint. However, if a vehicle is not a motor vehicle under this definition, then the vehicle need not comply with the agency's safety standards because such a vehicle is outside the agency's scope of authority. Applying this definition to the response units, NHTSA believes the response units are motor vehicles within the meaning of the Safety Act. In determining whether a vehicle which has both on-road and off-road uses is a motor vehicle, the agency looks at whether the vehicle uses public roads on a necessary and recurring basis. Applying this criteria to the response units, we believe that the response units have a primary function of highway transportation of personnel and equipment to the chemical spill site. NHTSA's safety standards specify different requirements for different types of motor vehicles. Therefore, in order to determine the occupant seating requirements for the response units, it is necessary to determine how these vehicles are classified under our regulations. NHTSA defines a 'truck' as 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment.' The tractor portion of the response unit has seating capacity for at least three passengers, but its primary use appears to be to draw the trailer. Therefore, it appears that this vehicle is a 'truck' for the purpose of Federal regulations. NHTSA defines a 'trailer' as 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.' NHTSA believes the trailer portion of the response units would be considered trailers for the purpose of Federal regulations. NHTSA has exercised its authority under the Safety Act to issue four safety standards relevant to occupant seating and restraint: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for all 'occupant seats' in passenger cars, multipurpose passenger vehicles, and trucks, and for the driver's seats in buses, except that the requirements do not apply to side-facing seats. Therefore, all 'occupant seats' in tractor portion of the response units must meet the requirements of Standard No. 207. Standard No. 207 does not apply to trailers, therefore, the seats in the trailer portion of the response units are not subject to the requirements of Standard No. 207. Standard No. 208 specifies occupant protection requirements based on vehicle type and seating position within the vehicle. Different requirements also apply depending on the GVWR of the vehicle. The discussion which follows is limited to vehicles with a GVWR greater than 10,000 pounds. As explained below, trucks are required to have, at a minimum, a lap belt at every designated seating position. As with Standard No. 207, Standard No. 208 does not apply to trailers. Therefore, the seats in the trailer portion of the response units are not required to have any type of safety belt at any seating position. The requirements for trucks with a GVWR of 10,000 pounds or more are contained in section S4.3 of Standard No. 208. Vehicle manufacturers have a choice of two options for providing occupant crash protection in trucks manufactured on or after September 1, 1990. Option 1 requires vehicle manufacturers to provide an automatic protection system at all seating positions that meets the frontal and lateral crash protection and rollover requirements. Option 2 requires vehicle manufacturers to install lap or lap/shoulder belts at every seating position. If a manufacturer chooses to comply with Option 2, the lap belt or pelvic portion of a lap/shoulder belt must have either an emergency locking retractor or an automatic locking retractor. Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. This standard applies to all seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. Thus, if seat belts are voluntarily installed at the seats in the trailer portion of the response units, the seat belts would be required to be comply with Standard No. 209. Standard No. 210 establishes strength and location requirements for seat belt anchorages installed in vehicles, where seat belts are required by Standard No. 208. Therefore, anchorages are required for the lap belts in the tractor, but are not required in the trailer. Although all of the safety standards cited in this letter do not apply to each seating position in your proposed emergency response unit, the agency nevertheless encourages additional consideration and application of those performance requirements that are appropriate to a safe design. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: aiam4572

"Dear Mr. Wolpe: Thank you for your letter to former Secretary Burnle on behalf of your constituent, Mr. Dennis Furr of Lansing, Michigan. I've been asked to respond to your letter since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety. Mr. Furr is concerned about the potential safety problems that may result if school bus seats are being overloaded. In particular, Mr. Furr asks whether NHTSA's Highway Safety Program Guideline (HSPG) No. 17, Pupil Transportation Safety (23 CFR /1204.4), is consistent with Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222), with regard to seating specifications. Mr. Furr is particularly interested in how manufacturers are calculating the number of seating positions on a bench seat. I am pleased to address your constituent's concerns. Before I begin, I want to note that we have answered a number of similar inquiries from Mr. Furr in past years. We have two sets of 'regulations' for school buses. The first, issued under the Vehicle Safety Act, includes our motor vehicle safety standards which apply to the manufacture and sale of new school buses. Compliance with these standards is mandatory for new vehicle manufacturers, and is enforced by this agency with civil penalties. FMVSS No. 222, with which your constituent is concerned, is one such safety standard. The second set of 'regulations,' or guidelines, for school buses was issued under the Highway Safety Act. Guidelines issued under this Act are not mandatory for the states, rather, they are recommended practices. Highway Safety Program Guideline No. 17, to which Mr. Furr frequently refers in his letter, consists of recommendations to the States for operating their school buses and pertains to Federal funding of State highway safety programs. Both FMVSS No. 222 and Guideline No. 17 contain specifications for school bus seating. Paragraph S4.1 of FMVSS No. 222 states: 'The number of seating positions considered to be in a bench seat is expressed by the symbol W, and calculated as the bench width in inches divided by 15 and rounded to the nearest whole number.' The guideline for seating accommodations in HSPG 17 states: Seating should be provided that will permit each occupant to sit in a seat in a plan view lateral location, intended by the manufacturers to provide seating accommodation for a person at least as large as a 5th percentile adult female, as defined in 49 CFR 571.3. Mr. Furr appears to see a conflict between the formula used in calculating the forces to be applied to the seats of large school buses under FMVSS No. 222, on the one hand, and the use by States and manufacturers of 13-inch seating positions for rating the capacity of a 39-inch seat, on the other hand. I believe that Mr. Furr's belief in the existence of a conflict rests on a misunderstanding. We view Standard No. 222 and HSPG 17 as complementary, not inconsistent. HSPG 17 reflects NHTSA's belief that all school bus passengers should be seated in the interest of safety. To that end, the guideline provides that there should be a seating position for each passenger and that the position should be at least large enough to accommodate a 5th percentile adult female. The hip width (sitting) of a 5th percentile adult female is 12.8 inches. The figure '15' in FMVSS No. 222's compliance formula is not a minimum requirement for the width of a seating position. It is the number which is used to establish the number of designated seating positions and ensures that the forces applied to the seat during compliance tests are reasonable reflections of the crash forces that would be involved in a real-world crash. It is also the number which ensures that the width of the smallest seat is approximately equal to the hip width of the 5th percentile female. That is consistent with HSPG 17 which provides that seating positions shall be at least large enough for a 5th percentile female. Use of the figure '15' in the FMVSS No. 222 formula results in a minimum seating position width of 12.67 inches (for a 38-inch wide seat.) That is only slightly smaller than the 12.8 inch hip width of the 5th percentile female. For a 39-inch wide seat, the single position width is 13 inches, which is slightly larger than the hip width of a 5th percentile female. It should be remembered, however, that the number of seating positions derived from the FMVSS No. 222 formula is not meant to be a measure of the absolute capacity of the bus for all size occupants. We recognize that, in practice, school buses transport a tremendously wide variety of student sizes. For example, a bus that may be capable of easily accommodating 65 preschool or elementary students may be capable of carrying only 43 high school students. When the bus is used to transport students of widely varying ages and sizes, reasonable accommodations may vary between those values. The decision on how many passengers may be comfortably and safely accommodated, therefore, is a decision that must be reached by the bus operator, in light of the ages and sizes of passengers involved. NHTSA does not have the authority under either the Highway Safety Act or Vehicle Safety Act to regulate how States use school buses. Therefore, NHTSA could not preclude a State from carrying more passengers on a bench seat than there are designated seating positions. However, this agency agrees with Mr. Furr that a student should not sit on a seat unless the student can sit fully on the seat instead of sitting only partially on the seat and thus only being partially protected by the compartmentalization. We believe that Mr. Furr's concerns as they apply to public schools would be best addressed by his working with the local school board and state officials. Mr. Furr is also concerned about a reference in our occupant crash protection standard (No. 208) to a 95th-percentile adult male occupant size. He asks why FMVSS No. 222 uses a 15-inch seat dimension, when FMVSS No. 208 references the 95th-percentile adult male occupant size in specifying occupant sizes which safety belts must adjust to fit. Both FMVSS No. 208 and FMVSS No. 222 are directed at providing occupant crash protection. Both of these standards set forth comprehensive requirements that are directed at protecting occupants likely to be inside a vehicle in a crash. With regard to school buses, the agency determined that the crash protection requirements should be developed taking into account the full size range of passengers typically riding on school buses. If we designed the force and deflection (energy-absorbing) characteristics of the seats for the 95th percentile males, the seats may be too stiff for a small child. Finally, Mr. Furr asks whether, when voluntarily installing safety belts on large school buses, States are violating Federal law by using S4.1 of FMVSS No. 222 in determining how many positions (and belts) there are on a bench seat. The answer is no. FMVSS No. 222 requires safety belts only for the passenger positions of small (10,000 pounds or less GVWR) school buses. Under S5 of the standard, belts on a small school bus bench seat are installed at 'W' seating positions, as determined under S4.1. If a State wishes to order belts on its new large school bus and to use the same method for determining the number of belts to be installed, the State may do so. I hope this information is helpful. If you have any further questions, please do not hesitate to contact me. Sincerely, Diane K. Steed";

ID: nht80-3.44

DATE: 08/29/80

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA; SIGNATURE BY STEPHEN P. WOOD

TO: Aston Martin Lagonda (1975) Limited

TITLE: FMVSS INTERPRETATION

TEXT: I have in hand your letter of July 31, 1980, and regret to inform you that the vehicle identification number (VIN) scheme which you propose is apparently not in compliance with U.S. Federal Motor Vehicle Safety Standard No. 115.

S4.5.2 and Table 1 of Standard No. 115 provide that the following information shall be decipherable from the five characters comprising the second section of the VIN for passenger cars: Line, Series, Body Type, Engine Type, Restraint System Type. A review of your Engineering Instructions and the accompanying drawings do not provide information concerning either the engine type or the restraint system type. Likewise, it is not clear whether your model designation is more appropriately characterized as line and/or series.

If the information omitted remains constant throughout a particular model, it will only be necessary for you to so state when deciphering your model code. For example, the following would be permissible:

Position 5 and 6: "V8" means V8 Volante model LHD, seat belt manual restraint system, V-8 engine with a displacement of 5.3 liters/326 cubic inches, a compression ratio of 8.3 and a net brake horsepower of .

We would also call to your attention that gross vehicle weight class is not required to be encoded in the VIN, although you are free to do so if you so choose.

Amongst the material furnished to the agency were drawings indicating the location of your confidential chassis identification number. As these are not required to be forwarded to the agency, I have taken the liberty of destroying them.

SINCERELY,

ENCLS.

ASTON MARTIN LAGONDA (1975) LIMITED

Frederic Schwartz Officer of the Chief Counsel, N.T.S.A.,

JULY 31, 1980

Dear Mr. Schwartz,

Vehicle Identification Numbering (17 characters)

Please find enclosed details upon which the Aston Martin Lagonda (1975) Ltd.

company has based its vehicle identification number (VIN) system, to be introduced with our 1981 model year cars.

The following documents have been enclosed to help clarify and explain the construction of the VIN system in detail:

(a) Construction drawings B97-16204/5/6 apply to Aston Martin V8 Saloon, Volante and Vantage (LHD) models respectively, B97-16224 applies to the Lagonda (LHD) (not currently certified in USA).

(b) Engineering Instruction number 205 gives a detailed explanation of the VIN construction. Engineering Instructions are sent to various departments within the Aston Martin organization and act as a reference and guide upon which work is carried out.

(c) Drawings A97-16226 and A97-16544 show the VIN plate designs and locations on the vehicle. The VIN is also stamped on the chassis member in characters with a minimum height of 7 mm (0.28 inches), Figures 1 and 2 in Engineering Instruction 205 show the location.

We have not sent details of our VIN system to anyone else, therefore we would appreciate your forwarding this letter and its contents to the relevant U.S. department, or advising accordingly.

KINDEST REGARDS,

R. Goldsmith Certification Engineer Safety and Emissions Department

ENGINEERING INSTRUCTION no. 205

Vehicle Identification Number (VIN) Systems

1. INTRODUCTION

AML will soon be operating two distinct Vehicle Identification Number (VIN) systems, one system applying to cars sold to U.S.A. and Canada and the other system applying to cars sold elsewhere in the world.

2. U.S.A. AND CANADA VIN SYSTEM (NHTSA)

1981 and subsequent model year cars sold to U.S.A. and Canada are required to have a 17 (seventeen) character vehicle identification number assigned. This means a series of arabic numbers and roman letters assigned to each motor vehicle for identification purposes and shall be sans sarif type face with a minimum height of 4 mm.

The VIN shall appear clearly and indelibly (i.e. stamped) on:

(a) the vehicle certification label (i.e. the brass plate, part number A97-13074, fixed to left hand 'B' post), and

(b) the VIN label part number A97-16226 and fixed in the same manner and position as the superceded label, part number 071-50-0160, on the dashboard.

2.1 VIN Content and Structure The VIN content and structure is as follows:

STRUCTURE

RACTER POSITION

1)

2) Assigned by BSI

3)

4) Gross vehicle weight class. 'C' = 4001 to 5000 lbf 'D' = 5001 to 6000 lbf

5)

6) Model

7 Not used

8 Model variant

9 Check digit (see R.G.'s memo for detailed explanation)

10 Model Year. 'A' = 1980

11 Plant of manufacture. 'T' = Tickfords

12 Driving position. 'T' = (Illegible Words) A = 1 J = 1 T = 3 B = 2 K = 2 U = 4 C = 3 L = 3 V = 5 D = 4 M = 4 W = 6 E = 5 N = 5 X = 7 F = 6 P = 7 Y = 8 G = 7 R = 9 Z = 9 H = 8 S = 2

VIN: S C F C V 8 0 S A Assigned value: 2 3 6 3 5 8 0 2 0 1 Weight factor: 8 7 6 5 4 3 2 10 0 9 Product: 16 21 36 15 20 24 0 20 0 9

2.1.1 World Manufacturers Identifier (WMI) Section

The WMI section is located in character positions 1 to 3 inclusive and is assigned by B.S.I. The code for all our models is SCF.

2.1.2 Vehicle Description Section (VDS)

The VDS is located in character positions 4 to 8 and is assigned by the manufacturer within the constraints laid down in the USA Federal Register, volume 44, number 57.

2.1.3 Vehicle Indicator Section (VIS)

The VIS is located in character positions 10 to 17 inclusive and is also assigned by the manufacturer within the constraints in the Federal Register.

2.1.4 The Check Digit

The check digit shall be determined and included in the VIN for each car sold to North America and Canada. It is determined by carrying out a mathematical computation that utilises each of the VIN characters according to the following formula:

(a) Each alphabetic character is assigned a numeric value according to the following table:

(b) The assigned value for each character is then multiplied by a weight factor that is dependent on VIN character position, see worked example below.

(c) The products are then added together and the sum divided by 11.

(d) The check digit is the remainder of the division, when this is 10 the check digit is X; when zero the check digit remains zero.

Worked example

VS Saloon (LHD) with assumed chassis number 12456 VIN: T L 1 2 4 5 6 Assigned value: 3 3 1 2 4 5 6 Weight factor: 8 7 6 5 4 3 2 Product: 24 21 6 10 16 15 12

Sum of products = 265, divide by 11 = 24 1/11

*Thus the check digit = 1 (to be inserted in ninth character of VIN)

2.1.4.1 Check Digit - Simplification

Because many of the VIN characters are common to each model the check digit

The scheme works thus:

(a) The Intermediate Check Digit remains constant for each model variant.

(b) Having allocated the sequential chassis number, multiply each digit by its weight factor and add these products to find the sum.

(c) Referring to Table 1(a), line-up the appropriate Sum and read across to the next column for the Sequential Number Check Digit (SCD).

(d) Next, refer to Table 1(b), and in the first column line-up the Sequential Number Check Digit, then line-up the Intermediate Check Digit; the point where the column and rows intercept is the corresponding VIN Check Digit.

(e) A worked example of the simplified Check Digit determination is shown below.

V8 SALOON APPROX. LHD

VIN Prefix Sequential Chassis No.

SCFCV80S ATL12678

4 3 2

Sum = 61 = 24+21+16

Sequential No. Check Digit = 6 [From Table 1(a)]

Intermediate Check Digit = 2

VIN Check Digit = 8 (Illegible Words)

(f) A summary of the Intermediate Check Digits for our model range is listed below: Model Driving Intermediate Instruction Drawing position Check Digit Number V8 Saloon Left HD 2 B97-16204 " Right HD 0 B97-16211 V8 Volante Left HD 5 B97-16205 " Right HD 3 B97-16212 V8 Vantage Left HD - B97-16206 " Right HD 8 B97-16213 Lagonda Left HD 4 B97-16224 " Right HD 2 B97-16225

* APPLICABLE (Illegible Words) VIZ (Illegible Words)

3. VIN SYSTEM - BEST OF THE WORLD (i.e. not applicable to USA or Canada)

The vehicle identification number (VIN) section on the brass plate, part numbers A97-15564/5 applicable to the Lagonda and V8 models respectively, will be completed by AML using the current sequential chassis numbering system. The plates will be embossed using stamps with a character of 4 mm minimum height. There will be no gaps or marks between the characters. The number will be finished with a dash, again without a gap, similar to the start of the number as shown in drawing A97-15564/5.

The chassis numbering (VIN) system is as follows:

(a) Lagonda : -LOOR13XXX-

(b) V8 Saloon : -V8SOR12XXX-

(c) V8 Volante : -V8COR15XXX- and (d) V8 Vantage : -V8VOR12XXX-

3.1 Lagonda VIN Structure Lagonda VIN Structure CHARACTER POSITION 1 -L Model 2 0 Not yet designated 3 0 Not yet designated, but J to be used for cars sold to Japan 4 R R = Right hand drive; L = Left hand drive 5 1) Chassis number model variant prefix 6 3) 7 X) 8 X) Sequential chassis number 9 X-

3.2 V8 VIN Structure V8 VIN STRUCTURE CHARACTER POSITION 1 -V) Model 2 8) 3 S,C or V Variant, i.e. S = Saloon; C = Convertible & V = Vantage 4 0 Not yet designated, but 'J' to be used for care sold to Japan 5 R or L R = Right hand drive; L = Left hand drive 6 I) Chassis number model variant prefix 7 2 or 5) 8 X) 9 X) Sequential chassis number 10 X-

3.3 Location of VIN Chassis Stamping

Bearing in mind the points outlined in 3. above, the VIN will also be stamped in the RHS of the chassis in the locations indicated in Figures 1 and 2 applicable to the Lagonda and V8 models respectively. The character heights shall be a minimum 7 mm high, and the number shall be legible when the car is completed and ready for sale, i.e. not covered by underseal.

APPROVED BY: S. COUGHLIN

PREPARED BY: A. GOLDSMITH

SAFETY & EMISSIONS: J. D. ORCHARD

Table 1

(a) Sequential No. Check Digit (SCD) Sum SCD Sum SCD Sum SCD 1 1 36 3 71 5 2 2 37 4 72 5 3 3 38 5 73 7 4 4 39 6 74 8 5 5 40 7 75 9 6 6 41 8 76 10 7 7 42 9 77 0 8 8 43 10 78 1 9 9 44 0 79 2 10 10 45 1 80 3 11 0 46 2 81 4 12 1 47 3 13 2 48 4 14 3 49 5 15 4 50 6 16 5 51 7 17 6 52 8 18 7 53 9 19 8 54 10 20 9 55 0 21 10 56 1 22 0 57 2 23 1 58 3 24 2 59 4 25 3 60 5 26 4 61 6 27 5 62 7 28 6 63 8 29 7 64 9 30 8 65 10 31 9 66 0 32 10 67 1 33 0 68 2 34 1 69 3 35 2 70 4

(b) VIN Check Digit

Intermediate Check Digit (Illegible Table)

ID: 3232yy

Mr. Robert W. Smith
President
Auto Safety Corporation
Box 424
Middletown, Delaware 19709

Dear Mr. Smith:

This responds to your letter of October 14, 1991, to Taylor Vinson of this Office, asking for a confirmation of your interpretation of Motor Vehicle Safety Standard No. 108, based upon a meeting with Mr. Vinson on August 15, l990.

You are developing a license plate frame that incorporates a "flashing/steady burning stop lamp", for use on passenger cars and motorcycles, and "an auxiliary flashing/steady burning stop lamp" for use on vans, minivans, and pickup trucks. You cite a letter of this agency to Bettie Lou Simcox, dated October 24, 1986, as authority for your understanding that Standard No. l08 allows the use of a flashing, steady burning stop lamp.

Standard No. 108 covers original motor vehicle lighting equipment, and lighting equipment that is intended to replace the original lighting equipment. It does not cover supplementary or novelty lighting equipment offered in the aftermarket. Mrs. Simcox asked us about the acceptability of an aftermarket stop lamp which, when the brake is applied, pulses before going into a steady burning mode. We informed Mrs. Simcox that her lamp was unacceptable as replacement equipment because Standard No. l08 requires original equipment stop lamps, and lamps designed to replace that equipment, to be steady burning in use, but that it would be permissible under Standard No. l08 as a supplementary stop lamp. For the same reason, your invention would not be prohibited by Standard No. l08 if it is offered in the aftermarket as a supplementary stop lamp, which we understand is your intent.

You should be aware that Standard No. 108 specifically requires motor vehicles to be equipped with one or more license plate lamps. We are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. l08. We therefore remind you of the prohibition in the National Traffic and Motor Vehicle Safety Act that a manufacturer, distributor, dealer or motor vehicle repair business may not render inoperative, in whole or in part, a device such as the license plate lamp that has been installed in accordance with a safety standard such as Standard No. 108. Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:ll/l5/9l