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Interpretation ID: nht75-3.10

DATE: 06/02/75

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Tiger Tanks; Division of Faull Enterprises, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 28, 1975, concerning the manufacture and installation of replacement tanks for Dodge, Ford, and Chevrolet vans.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to replacement fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems (Standard No. 301, Fuel System Integrity). Thus, if installation of your replacement tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563). That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

Recent amendments to the Traffic Safety Act (Pub. L. 93-492) prohibit any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard (@ 108(a)(2)(A)). Therefore, even if installation of your replacement tank occurred after the first purchase of the vehicle, the vehicle's compliance with the fuel system integrity standard would still be mandatory where one of the above named persons performed the installation. If the replacement tank caused the fuel system to no longer comply with the safety standard, the installer would have rendered inoperative a system installed in compliance with Standard 301.

The Traffic Safety Act authorizes the Secretary of Transportation to make determinations as to whether items of motor vehicle equipment contain defects which relate to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to remedy the defect and notify purchasers of the hazard. Therefore, even though replacement fuel tanks are not the subject of a standard, they still must be designed for safety.

In addition, the Bureau of Motor Carrier Safety regulates interstate carriers, including fuel systems for operational and auxiliary equipment. These regulations might be of interest to you and are enclosed. Your attention is directed to the section concerning fuel systems, pages 51 through 54.

SINCERELY,

April 28, 1975

National Highway Traffic Safety Administration Department of Transportation

We wish to be informed as to what information is required of us to obtain your approval on our replacement fuel tank for Dodge, Ford and Chevy vans.

We are currently approved by the State of California Air Resources Board for the manufacturing installation and distribution of our fuel tank. (enclosure)

Our replacement fuel tank does not alter or change any standard fuel system or structual entities of the vehicle.

We are only adding an additional fuel capacity.

We are currently negotiating a contract with a company who is placing quite a large order and they are requesting that we have your approval.

We have checked with Ford Motor Company, Chrysler Corporation and General Motors Corporation and they have informed us that we do not need any approvals from them.

Thanking you in advance.

Alfred H. Faull President

Tiger Tanks Division of Faull Enterprises, Inc.

A Division of Faull Enterprises, Inc.

REPLACEMENT FUEL TANKS FOR DODGE, FORD, CHEVY VANS AND MINI MOTOR HOMES

* Construction of long ternes steel-lead coated inside and out.

* Made of the same metal as the Ford Motor Company. The Chrysler Corporation and General Motors Corporation use on all original fuel tanks.

* Construction of heavy duty 16 guage steel.

* Seam welded.

* New sending unit and mounting hardware included.

* Connects back to original equipment.

* Pressure tested.

* No inside oil coating to dissolve.

* No plastic lining to peel and clog fuel lines and carburetors.

* No rusting to clog carburetors.

* No exterior paint to peel and cause rusting.

* Approved by the California Air Resourse Board. MODEL WHEELBASE YEAR APPROX. CAPACITY - DODGE ALL WHEELBASE 70-75 48 gallons net FORD ALL WHEELBASE 68-75 46 gallons net CHEVY/GMC ALL WHEELBASE 71-75 45 gallons nets

O.E.M. SUGGESTED RETAIL $ 79.00 not installed $ 125.00 not installed $ 105.00 installed $ 150.00 installed

F.O.B. Carson, Calif. Terms are C.O.D.

Prices subject to change without notice.

Orders of 10 or more units - $ 69.95 per unit.

State of California AIR RESOURCES BOARD

EXECUTIVE ORDER F-39 Relating to the Accreditation of Auxiliary Gasoline Fuel Tank Evaporative Loss Control System

TIGER TANKS DIVISION OF FAULL ENTERPRISES INC.

Pursuant to the authority vested in the Air Resources Board by Sections 39106.5 and 39175 of the Health and Safety Code; and

Pursuant to the authority vested in the undersigned by Section 39023 of the Health and Safety Code;

IT IS ORDERED AND RESOLVED: That Tiger Tanks auxiliary gasoline fuel tank evaporative loss control system is accredited for installation on vehicles subject to evaporative emission control requirements and originally equipped with activated carbon canister type control systems.

This accreditation is for systems serving up to 100 gallons of total fuel storage. For each 50 gallons of fuel storage capacity the vapors shall be vented to a 500 to 625 gram capacity activated carbon vapor storage canister.

This Executive Order shall, without further action by the Executive Officer, cease to be of effect if fuel evaporative loss emission standards more stringent than those in effect on the date of this Order are established and made applicable to any vehicle for which the manufacturer's system is hereby accredited, unless prior thereto the manufacturer applies for and obtains from the Executive Officer, based upon a showing that its system complies with such more stringent standards, an appropriate amendment to this Order or a new Executive Order.

The manufacturer must obtain prior approval from the Air Resources Board before any production changes are made on the gasoline fuel evaporative loss control system that would affect evaporative emissions, or before the system is sold, offered for sale, or advertised under a different name, whether by the manufacturer or any other person.

The Department of Motor Vehicles, the California Highway Patrol, and the Bureau of Automotive Repair will be notified by copy of this order and attachment.

Executed at Sacramento, California, this 10th day of December, 1974.

GEORGE J. TAYLOR

WILLIAM SIMMONS FOR Executive Officer

NET GALLONS 48

(Graphics omitted)

NET GALLONS 46

LONG WHEEL BASE ONLY

NET GALLONS 45