Interpretation ID: aiam0369
General Manager
Toyota Motor Co.
Ltd.
Lyndhurst Office Park
1099 Wall Street West
Lyndhurst
New Jersey 07071;
Dear Mr. Nakajima: This is in reply to your letter of June 2, 1971, requestin clarification of S4.3 of FMVSS No. 110, which requires a placard containing specified information to be 'permanently affixed to the glove compartment door or an equally accessible location.' Your letter list seven locations on the vehicle (steering column, lower instrument panel pad or knee pad forward of the front seat occupants, sun visor, inside panel surface of the driver's door, door-latch post next to the driver's seat, door edge that meets the door-latch post next to the driver's seat, and door edge that meets the hinge pillar next to the driver's seat) and asks whether each would be considered an 'equally accessible location' under the standard.; The phrase 'glove compartment door or equally accessible location' i intended to require the placard to be affixed to a location where, like the glove compartment door, it can not only be easily referred to, but where it will also be relatively free from exposure to substances that may destroy it or render it illegible. With reference to your list of seven locations, we cannot determine without the specific configuration of the components involved whether placing the placard at any point on the component will meet the requirement. however, we believe the placard could be placed at some point on each of these components or locations so that the requirements of the standard would be met.; Please let us know if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel