Interpretation ID: nht91-5.32
DATE: September 3, 1991
FROM: D. G. Kong -- General Manager, Certification Business Dept., KIA Motors Corp.
TO: Andrew J. Sklover -- Special Assistant to the Administrator, NHTSA
TITLE: None
ATTACHMT: Attached to letter dated 10-7-91 from Paul Jackson Rice to D. G. Kong (A38; Std. 216, Part 567)
TEXT:
We are pleased to get to give our best regards to you this time since your visit to our company last year.
Since then, we are trying to do our best for developing our future models suitable for American market in accordance with the guidance of NHTSA.
For the lack of information on USA safety certification, we are in need of your help for the followings: (A) FMVSS 216 Roof Crush Resistance for Convertibles : According to S3(c) of FMVSS 216 Roof Crush Resistance, convertible vehicles are exempted from application for this rule, we understood. We'd like to know the clear & detailed definition of convertibles. Let's make an example for your reference. The soft roofline of ISUZU Amigo (Sports Utility Vehicle) is composed of half hard top with steel and half soft top with plastic or special cloth. Is it called by convertible in connection with application of FMVSS 216 requirements effective September 1, 1993? (Soft top can be detachable in use.)
(B) Submitting reports to NHTSA and state governments: In relation to USA Safety certification, there are lots of laws & regulations of federal/state goverments, we know. What regulations in addition to FMVSS do we should follow (expecially in state regulations) and what reporting (such as, Bumper-Indiana and VIN Reporting-NHTSA) do we have to submit when we proceed USA Safety Certifiction? We'd like know the relationship of laws and regulations between federal states.
We're wondering if you are in charge of these queries or not, but you are kindly requested to deliver the message to the man in charge.
We'll do endeavor to keep up with the line of NHTSA to improve the safety of motor vehicles and at last wish you and your family every happiness.