Interpretation ID: nht73-6.23

DATE: December 10, 1973

FROM: Richard B. Dyson -- Assistant Chief Counsel, NHTSA

TO: Robert R. Aronson -- President, Electric Fuel Propulsion Corp.

TITLE: None

ATTACHMT: Attached to letter dated 11-26-73 from Robert R. Aronson to Lawrence Schneider (Chief Counsel, NHTSA)

TEXT:

This is in reply to your letter of November 26, 1973, inquiring about the applicability of Standard No. 301 to your vehicles' gasoline-powered water heaters.

Standard No. 301 was promulgated in order to reduce the incidence of deaths and injuries resulting from fuel-related fires. The standard seeks to accomplish this end by specifying performance requirements which must be met by a motor vehicle's fuel system. Although the fuel systems primarily regulated by the standard are those which propel the vehicle, nothing in the standard limits its application to those systems. A fuel system which powers another aspect of the vehicle's operation, such as the gasoline- powered Stewart Warner Water Heater, is susceptible to the same hazards as the more commonly encountered fuel system, and thus they must be regulated in the same manner in order to fulfill the purposes of Standard No. 301.

In summary, the 2-quart fuel tank to which you refer is subject to the requirements of Standard No. 301.