Interpretation ID: nht69-2.43

DATE: 12/11/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Mercedes-Benz of North America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: RE: CONSUMER INFORMATION

We have received your submittal of consumer information in response to the requirements of 49 CFR Part 375. The regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.

The Consumer Information section on Vehicle Stopping Distance, 49 CFR @ 375.101, specifics that the information presented shall contain "the most adverse combination of maximum or lightly loaded vehicle weight and complete loss of braking in any one of the vehicle brake subsystems." In your submittal, you have presented information for failures in each of the front and rear subsystems, instead of selecting the most adverse combination of weights and system failures. This is likely to confuse consumers attempting to compare vehicles of different manufacturers, and fails to satisfy the requirement that the information shall be submitted "in essentially the form illustrated in Figure 1" of @ 375.101.

We will be glad to answer any questions that you may have with respect to the requirements of these or other motor vehicle safety regulations and standards.