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Interpretation ID: nht69-2.44

DATE: 12/11/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Chrysler Corporation

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. That 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.

Each of the three substantive sections establishing requirements for Vehicle Stopping Distance, Tire Reserve Load, and Acceleration and Passing Ability respectively specify that the information shall include, "in essentially the form illustrated in Figure 1," a description of the vehicles to which the table applies. Each of the figures in the regulations shows the vehicle description in close proximity to be tables. This element is missing from your compilation of information. Instead you have provided a master key in the front of the booklet, applying to all the tables within. Not only does this not satisfy the requirement in respect to form, but we have found in attempting to transcribe the information into a standard format that it is very difficult to interpret in some cases; and would surely cause confusion to consumers attempting to use it.

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.