Interpretation ID: nht90-2.96
TYPE: Interpretation-NHTSA
DATE: June 27, 1990
FROM: Olivier M. Sprangers -- A.T. Kearney, Inc.
TO: James T. Brooks -- Department of Transportation, Federal Highway Administration, Office of Traffic Operations HTO-21
TITLE: None
ATTACHMT: Attached to letter dated 1-8-91 from Paul J. Rice to Olivier M. Sprangers (A37; Std. 125); Also attached to letter dated 8-20-90 from Harry B. Skinner to Olivier M. Sprangers (OCC 5444)
TEXT:
With reference to our telephone conversation of Monday 25th of June, we'd like to ask your help in preparing the best advice for our customer. There are in fact two major concerns, for which we'd appreciate your written comments.
The first one concerns the process of approval of a new triangle. Basically, the company has designed the product such that it fits within the regulations you have supplied us, namely 49 CFR Ch. III par. 393.95 and 49 CFR Ch V 571.125. The company inten ds to have this verified by a neutral testing organisation. Is this a required or advisable step, and are there any other steps which have to be taken in order to be allowed to start selling the product in the US market?
The second concern is about the term "collapsible" in said regulations. Most traffic triangles are collapsible in the sense that the two sides ("legs") pointing upwards can be flapped down, and the supporting feet can be turned resulting in a flat and th in, long package. This company's product, allows only for the supporting feet to be turned and brought into the same flat surface as the triangular, resulting in a flat, triangle shaped thin package. Would this structure still be within the meaning of the term "collapsible"?
Next to these two concerns, we'd highly appreciate your advice concerning other official government people to contact, who could offer valuable advice in the application of this product.
We highly appreciate your time and efforts in this matter, also on behalf of our client.
We'd kindly welcome your answer within two weeks, if possible.