Interpretation ID: nht92-9.58

DATE: January 7, 1992

FROM: Stephen C. Bartch -- Applications Engineer, Quigley Motor Company, Inc.

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/18/92 from Paul Jackson Rice to Stephen C. Bartch (A39; Part 567; Std. 301)

TEXT:

We propose to convert the Ford E-series vans to our 4X4 drive system; however, the tank in the 1992 vans interferes with our transfer case placement.

After much consideration and examining other Ford tank arrangements on 4X4 vehicles, we came to the conclusion that to keep certification costs down and still show due-care in reference to FMVSS 301, we should either:

A. find a tank manufacturer that can build a tank with identical attachments as the OEM tank, or B. modify the OEM tank to eliminate the interference.

We found a tank supplier who can manufacture the tank to our specifications, so we can pursue both options.

The question that some of our customers are asking is about the legality of our fuel tank retrofit in regards to FMVSS 301. Could you summarize in writing our responsibilities regarding FMVSS 301 and state that we are not required by law to do crash testing on our vehicles?

Thank you for your cooperation and willingness to accommodate us.