Interpretation ID: aiam0376
Esq.
Messrs. Modrall
Seymour
Sperling
Roehl & Harris
Public Service Building
P.O. Box 2168
Albuquerque
New Mexico 87103;
>>>Re: *Gigler v. Volkswagen*<<< Dear Mr. Harringan: In your letter of June 16 to Roman Brooks of this agency you ask fo background information on Federal Motor Vehicle Safety Standard No. 301, *Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections,* effective January 1, 1968.; Section 103(h) of the National Traffic and Motor Vehicle Safety Act o 1966 required that the initial safety standards be 'based upon existing safety standards.' Standard No. 301 was based upon General Services Agency Standard No. 515/26, *Fuel Tanks and Tank Filler Pipes,* effective October 13, 1967. As you know, the GSA standards were applicable only to vehicles purchased by the Federal Government. The two standards, however, are not identical, as an example, Standard No. 301 includes fuel tank connections, while GSA Standard No. 515/26 included a rear end collision test at 15 miles per hour. Perhaps GSA can provide you with background information on their standard if you deem it essential to your case.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel