Interpretation ID: aiam0340

Andrew R. Hricko, Esq., General Counsel, Insurance Institute for Highway Safety, Watergate Six Hundred, Washington, DC 20037; Andrew R. Hricko
Esq.
General Counsel
Insurance Institute for Highway Safety
Watergate Six Hundred
Washington
DC 20037;

Dear Mr. Hricko: This is in reply to your letter of April 30, 1971, requesting a interpretation of the terms 'cooling system' and 'fuel system' as used in Motor Vehicle Safety Standard No. 215.; You first ask whether 'cooling system' includes the various component of the vehicle's air conditioning system. The term is not intended to include the air conditioning system.; Your second question is whether 'fuel systems' would include pollutio control vapor cannisters (sic) and other components used to reduce fuel emissions. If such components contain fuel or fuel vapor they are considered to be a part of the fuel system.; Please advise us if further clarification is needed. Sincerely, Lawrence R. Schneider, Acting Chief Counsel