Interpretation ID: nht76-3.14

DATE: 04/14/76

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: National Automobile Theft Bureau

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 8, 1976, concerning "track sheets" and "autotels."

Section S4 of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials, lists those components of a motor vehicle that must comply with burn resistance requirements. I have enclosed a copy for your information. An "autotel" under the back seat, between the frame and the body, or pasted to the top of the gas tank does not fall within the ambit of the standard. Consequently, it is our view that this most important and effective deterrent to vehicle theft is not discouraged by any existing motor vehicle safety standard.

The National Highway Traffic Safety Administration has proposed that Standard No. 302 be amended to include all materials exposed to the occupant compartment air space. If this amendment is adopted, an "autotel" under the seat presumably would fall within the purview of the standard. In this case, the "autotel" could not burn at a rate of more than 4 inches per minute. We believe that this would not prove an impediment to the continuation of the "autotel" program as flame-retardant paper is readily available.

If I can be of further assistance in this matter, please do not hesitate to contact me.

SINCERELY,

NATIONAL AUTOMOBILE THEFT BUREAU

January 8, 1976

Dr. James Gregory, Administrator NYTSA Department of Transportation

We are writing this on behalf of our own investigative efforts as well as for law enforcement generally.

Each auto manufacturer in the United States when assembling a car uses what is called a track sheet or autotel. This piece of paper, and in some cases two pieces of paper, contains detailed information on the identification of various parts of the car being assembled and contains the numbers and information necessary to positively identify that vehicle.

Over the years, auto theft investigators, including our own investigators and those in law enforcement, have been able to identify hundreds of stolen cars by use of this material even though the numbers stamped into the frames and affixed to the dashboard have been changed or obliterated by thieves.

This paper is usually secreted in some portion of the vehicle, sometimes put under the back seat, sometimes between the frame and the body, and in one particular make of car is Scotch taped onto the top of the gas tank.

We have been informed that there is a possibility that this practice might be regarded as adding to the flammability of the interior of a car and, to our knowledge, at least one manufacturer has discontinued this invaluable aid to automobile identification because of the possibility that these tracks might be prohibited by regulation.

I would request that you consider the extreme value of the inclusion of auto tel in the vehicles and, also, consider the very minimum possibility of these contributing to any fire hazard in the car.

We would like a clarification of your Agency's position in this matter in order that we may request the manufacturers to continue these tracks.

We would appreciate any consideration you can give our request.

Michael J. Murphy President

cc: HON. WILLIAM T. COLEMAN -- SECY. OF TRANSPORTATION; HON. EDWARD LEVY -- ATTY. GENERAL; JOHN CARSON -- BRANCH CHIEF, CONTROLS & DISPLAYS, NHTSA