Interpretation ID: aiam2213
Director
Automotive Safety Engineering
General Motors Corporation
General Motors Technical Center
Warren
MI 48090;
Dear Mr. Martin: This is in response to General Motors' October 28, 1975, petition t amend Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity. You requested an amendment that would permit the removal of trailer hitches before testing a vehicle for compliance with the rear moving barrier crash requirements. For the reasons set out below, the petition is denied.; As far as the National Highway Traffic Safety Administration (NHTSA) i concerned, the primary issue presented by the petition is whether the presence of a trailer hitch will compromise the crashworthiness of a vehicle or, in particular, whether it will diminish the integrity of the vehicle's fuel system. We believe that a new vehicle that is delivered to a purchaser with a trailer hitch, be it removable or permanently attached, should be in compliance with all standards without further modification.; You have suggested that requiring original equipment hitches to b attached during barrier crash testing would not have a significant effect on motor vehicle safety because such hitches make up only 5 percent of the trailer hitch market and there is no standard applicable to hitches that are sold in the aftermarket. However, Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specifies that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard...<<<; Therefore, aftermarket trailer hitches must also be installed in such way that compliance with Standard No. 301-75 is preserved.; You have also suggested that the rear moving barrier crash test i inappropriate as applied to vehicles that have trailer hitches attached, because the rigid, flat-faced moving barrier would but an unrealistically concentrated load on a trailer hitch. The NHTSA disagrees with this argument. Because the effect of Standard No. 215 has been to control the height and contour of bumpers and increase their rigidity, a vehicle's performance in the test prescribed in the standard does in fact tend to reflect its performance on the road.; For these reasons, the NHTSA has concluded that the amendment you hav suggested would diminish the level of motor vehicle safety and, therefore, that your petition should be denied. Indeed, for this agency to do otherwise would violate Section 108 of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392 note), concerning amendment or repeal of the fuel system integrity standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;