Interpretation ID: aiam3218
Manager/Information Systems
Harley-Davidson Motor Co.
Inc.
P.O. Box 653
Milwaukee
Wisconsin 53201;
Dear Mr. Fink: This is in reply to your letter of January 30, 1980, to Mr. Vinson o this office asking for an opinion whether S5.2.5 of Motor Vehicle Safety Standard No. 123 permits a passenger footboard of the nature you are considering for production.; S5.2.5 requires that 'footrests' be provided that, for passengers, fol rearward and upward when not in use. 'Footrest' is not defined but we view it as a term sufficiently broad to encompass both the round footpegs which predominate in the industry, as well as the footboard you propose to use. From the blueprint that you enclosed, the footboard when folded appears to be well within the permanent vehicle structure, and thus to meet the intent if not the letter of S5.2.5. We therefore see no legal reason why you may not introduce it into production.; Sincerely, Frank Berndt, Chief Counsel