Interpretation ID: 1983-2.40

TYPE: INTERPRETATION-NHTSA

DATE: 08/08/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: C. B. Bright Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Washington, D.C. 20590

August 8, 1983

Mr. C. B. Bright, Jr. C. B. Bright Motor Co. Route 1 Ashland, MS 38603

Dear Mr. Bright:

This is in reply to your letter of July 19, 1983, to Mr. Vinson of this office. You have asked whether you are violating any Federal standards or regulations by adding "right side steering, accelerator, brakes & turn signal controls to rural mail carriers delivery vehicles (cars, pickup, jeeps, etc.)." You have told us that you do not modify in any way the left hand side controls with which the vehicle was originally equipped.

Assuming that your modifications do not affect the performance of any of the systems with which the vehicle was equipped by its original manufacturer, your conversion operations would not be prohibited by the National Traffic and Motor Vehicle Safety Act. However, with respect to any new vehicle that you modify which has not yet reached its first purchaser for purposes other than resale, you are required to affix a label identifying you as the alterer and certifying that the vehicle as altered meets all applicable Federal motor vehicle safety standards. This is required by Title 49 Code of Federal Regulations, Section 567.7. I enclose a copy of Part 567 for your information.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

C. B. BRIGHT MOTOR CO. Ashland, Miss. 38603

July 19, 1983

MR. TAYLOR VINSON OFFICE OF CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION NUMBER 400 7th. ST. S.W. WASHINGTON, D.C. 20590

MR. TAYLOR:

IN REGARDS TO OUR TELEPHONE CONVERSATION ON OUR ADDING RIGHT SIDE STEERING, ACCELERATOR, BRAKE & TURN SIGNAL CONTROLS TO RURAL MAIL CARRIERS DELIVERY VEHICLES ( CARS, PICKUPS, JEEPS & ETC.).

WE DO NOT CHARGE UP, MODIFY OR TAKE OUT ANY OF THE FACTORY INSTALLED CONTROLLS THAT HAVE BEEN CERTIFIED BY THE FEDERAL GOVERNMENT. CONTROLS MEANING STEERING, BRAKE, ACCELERATOR AND TURN SIGNAL.

WE HAVE ADDED THESE DUAL CONTROLS TO MAIL CARRIER DELIVERY VEHICLES SINCE 1958 AND THE USE AND SAFETY HAVE BEEN PROVED BEYOND ANY DOUBT.

I WOULD LIKE TO KNOW IF WE VIOLATE ANY STANDARDS OR REGULATIONS WHEN WE ADD THE DUAL CONTROLS ( STEERING, BRAKE, ACCELERATOR AND TURN SIGNAL CONTROL FOR RIGHT SIDE USE OF VEHICLE.).

ENCLOSED IS A COPY OF A LETTER FROM THE NATIONAL PRESIDENT OF THE NATIONAL RURAL LETTER CARRIER'S ASSOCIATION.

I SINCERELY THANK YOU FOR THE KINDNESS AND CONSIDERATION YOU GAVE ME BY PHONE.

SINCERELY,

C. B. BRIGHT

NATIONAL RURAL LETTER CARRIERS ASSOCIATION

February 8, 1983 Mr. C. B. Bright Committeeman, Mississippi Rural Letter Carriers' Assn. Ashland, Mississippi 38603

Dear C. B.

This is in response to our telephone conversation concerning the dual controls which you manufacture and install on vehicles for rural carriers.

I advised you I would write you a letter relative to my own use of the dual controls. For the last several years I served on Route #1, Palestine, Arkansas. I used a vehicle equipped with the dual control system. That was during a period that ended in September, 1977. At that time, I assumed the duties of a Na-tional Officer and I have not carried a rural route since that time.

My own personal experience with the dual controls proved to be completely satisfactory, both from an operational and a safety standpoint. The steering was completely functional and the accelerator and brakes were also without fault.

******Letter not complete due to poor copy.