Interpretation ID: nht72-3.10

DATE: 09/07/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Kennedy, Holland, DeLacy and Svoboda, Attorneys at Law

TITLE: FMVSS INTERPRETATION

TEXT: Your letter dated July 27, 1972, to the Department of Commerce, regarding information pertaining to the National Traffic and Motor Vehicle Safety Act of 1966, initial standards, was referred to this office for reply.

The National Traffic and Motor Vehicle Safety Act of 1966, in establishing the legislative basin for the Federal Motor Vehicle Safety Standards, required that the initial standards, to the maximum extent possible, be based on existing safety standards. An Advance Notice of Proposed Rule Making, soliciting suggestions, opinions, and proposals for consideration in promulgating the initial standards, was published in the Federal Register on October 8, 1966. Paragraph S3.3(d) of the initial Motor Vehicle Safety Standard No. 201 was based on Paragraph S3.2.5 of Federal Standard No. 515/3a, which was published in the Federal Register on July 15, 1966, (31 F.R. 9628), after consideration of the comments received in response to the Advance Notice. I have enclosed a copy of Standard No. 515/3a.

Thank you for your letter. Your interest in automotive safety is appreciated.