Interpretation ID: nht76-5.73

DATE: 02/10/76

FROM: JAMES B. GREGORY -- NHTSA ADMINISTRATOR

TO: S. L. TERRY -- VICE PRESIDENT PUBLIC RESPONSIBILITY AND CONSUMER AFFAIRS CHRYSLER CORPORATION

TITLE: N40-30

ATTACHMT: LETTER DATED 1/22/76 FROM S. L. TERRY -- CHRYSLER CONSUMER AFFAIRS TO JAMES B. GREGORY -- NHTSA ADMINISTRATOR

TEXT: Dear Mr. Terry:

This is in response to your letter of January 22, 1976, in which you discussed Chrysler's position with respect to the recently proposed amendment of Standard No. 105-75 that would make a low brake fluid level indicator optional instead of mandatory. You asked that we provide assurance that if the proposal is not adopted, the existing requirement for the indicator will be delayed, in recognition of the fact that manufacturers have passed the latest point at which money must be committed for engineering and tooling the indicator for September production.

I will hereby provide that assurance. We recognize that if manufacturers do not delay their financial commitment past the usual period for preparation to meet a requirement, when the agency proposes to delete the requirement, the money is likely to be wasted even if the agency proceeds as proposed. We expect manufacturers to hold off their commitment of tooling and other expenses for a requirement that we have proposed to delete, and if we should decide not to go ahead with the proposal, we will take the required leadtime into account in resetting the effective date.

Sincerely,