Interpretation ID: 1984-4.3

TYPE: INTERPRETATION-NHTSA

DATE: 12/13/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Comfort Crew, Inc. -- William E. Hedenberg, President

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William E. Hedenberg President Comfort Crew, Inc. 716 South Milwaukee Avenue Wheeling, Illinois 60090

This responds to your October 5, 1984 telephone call to the National Highway Traffic Safety Administration (NHTSA) requesting further information on the certification requirements applicable to the air suspension systems you manufacture. You previously requested information on the certification requirements by letter to this agency dated August 13, 1984. In our response, we informed you that there are no standards that presently apply to air suspension systems. We further stated, however, that persons installing the suspension system on new vehicles prior to their first sale for purposes other than resale would have to certify that the vehicle, as altered, continues to comply with all the safety standards affected by the alteration.

In your telephone call, you asked what standards, in our opinion, would be affected by the installation of the suspension system. In addition, you asked what kind of information should be maintained by you and provided to the persons installing your air suspension system to enable such persons to certify that the vehicle continues to comply with the safety standards affected by the alteration.

It is impossible for the agency to identify all the standards that might be affected by your system since the alterations made to install your system presumably vary from vehicle to vehicle. For example, based on the location and configurations of the vehicle's fuel system, the installation of your system could have an effect on Standard No. 301, Fuel System Integrity. So that you may be aware of all the vehicle systems that are currently covered by Federal motor vehicle safety standards, we have enclosed a sheet explaining how to obtain additional information on the standards.

You could confer with the manufacturers of the vehicles on which you recommend installation of your air suspension system to learn which, if any, safety standards they feel might be affected by the system's installation in those specific vehicles. With this information, you could conduct further testing or undertake engineering analyses of your suspension system as mounted on the vehicle to determine whether installation of your device will affect a vehicle's compliance. If you can assure yourself that the vehicle as altered will continue to comply with the safety standards, this information could aid the installer of the equipment in certifying that the vehicle remains in compliance.

Sincerely,

Frank Berndt Chief Counsel

Enclosure