Interpretation ID: aiam3457
Sales Manager
Composite Cylinder Division
Luxfer USA Limited
P.O. Box 5300
Riverside
CA 92507;
Dear Mr. Sekermestrovich: This responds to your letter of July 2, 1981, seeking confirmation tha DOT approval is not required for compressed gas tanks that are to be used as part of an automobile fuel system.; Your determination that DOT approval is not required is correct. Th National Highway Traffic Safety Administration issues, pursuant to the National Traffic and Motor Vehicle Safety Act, safety standards and regulations governing the manufacture of motor vehicles and motor vehicle equipment. However, the agency does not pass approval on any vehicle or piece of equipment prior to its introduction in the market place. It is up to the manufacturer to certify, on the basis of due care, that its vehicles or equipment comply with all applicable Federal motor vehicle safety standards.; We note that the term 'manufacturer' is defined by section 102(5) o the National Traffic and Motor Vehicle Safety Act as 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, *including any person importing motor vehicles or motor vehicle equipment for resale*.' Emphasis added. The agency's enforcement program is based on compliance testing of vehicles or equipment that have already been certified by the manufacturer.; We are enclosing for your information a discussion which sets forth th implications under Federal law of converting gasoline-powered vehicles to use propane or other gas, as well as a general discussion of auxiliary fuel tanks. From that discussion, you will see that there are no safety standards directly applicable to propane fuel tanks as pieces of automobile equipment. There are, however, specifications under the Bureau of Motor Carrier Safety regulations relating to propane fuel systems on commercial vehicles or to tanks used for shipment of propane gas in interstate commerce. If your tanks will be used on other than private vehicles, these regulations may be of interest to you. For further information, you may contact Mr. W. R. Fiste of the Bureau of Motor Carrier Safety (202-426-0033).; We have also enclosed, at your request, copies of Safety Standard No 301, *Fuel System Integrity*, and 49 CFR Part 567, *Certification*.; Sincerely, Frank Berndt, Chief Counsel