Interpretation ID: aiam4230
Terralab Engineers
3585 Via Terra
Salt Lake City
UT 84115;
Dear Mr. MacGregor: Thank you for your letter of August 28, 1986, to Stephen Oesch of m staff concerning Standard No. 301, *Fuel System Integrity*. You asked whether the performance requirements of the standard would apply to a propane-fired engine block heater. You explained that the heater has its own fuel system that is independent of the vehicle's fuel system. As explained below, a propane-fired heater would not be covered by Standard No. 301.; Standard No. 301 sets performance requirements for the fuel system use in certain motor vehicles. The heater you have described apparently does not have any connections to the fuel tank or fuel lines of the vehicle. Instead, the heater has its own propane fuel system. Since the heater is not connected to the vehicle's fuel system, it would not be covered by the standard. Even if the heater were connected to the vehicle fuel system, it would not have to meet the performance requirements of the standard, since it is a propane-fired heater. S3 of Standard No. 301 limits the application of the standard to vehicles that use a fuel with a boiling point above 32 degrees Fahrenheit. Propane has a boiling point below 32 degrees Fahrenheit.; Even though the heater is not covered by the requirements of Standar No. 301, it would be considered an item of motor vehicle equipment. I have enclosed a copy of an information sheet that describes how our regulations, including those on defect notification and remedy campaigns, apply to equipment manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel