ID: nht94-2.59

TYPE: Interpretation-NHTSA

DATE: April 25, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: David A. Scott -- President, RKS International L.L.C.

TITLE: None

ATTACHMT: Attached to letter dated 3/8/94 from David A. Scott to John Womack (OCC-9783)

TEXT:

This responds to your letter of March 8, 1994, asking for information about this agency's regulations regarding importation and sale of motor vehicles and motor vehicle equipment.

You intend to import "fiberglass kit cars." The cars may be imported "either disassembled or partially assembled." Your company "will then be providing and/or installing American parts in the U.S. for the major mechanical portions like engines, transmissions, suspension systems, tires, etc."

It appears from your letter that you intend to import, items of equipment, either individually or as part of a larger assembly, which, after entry into the United States, will have the drive train and related components installed that are necessary to complete its manufacture as a motor vehicle. For purposes of this interpretation, it is unimportant whether the equipment is imported as individual items, or assembled into a vehicle lacking a power train.

Some items of motor vehicle equipment are subject to the Federal motor vehicle safety standards (FMVSS). In order to be imported into the United States, they must comply with all applicable FMVSS. Passenger car equipment that must comply includes brake hoses, brake fluid, lamps and reflectors, tires, glazing material, and seat belt assemblies. It is mandatory that all these items (except lamps and reflectors) beat a DOT symbol in order to be imported; the symbol is the manufacturer's certification of compliance with the FMVSS. It is optional for lamps and reflectors to be marked with the DOT symbol. If they are not marked, permissible options include a certification statement attached to the equipment item or on the container in which the item is shipped.

When assembly of the vehicle is completed in the United States, its assembler must satisfy itself that it conforms to all applicable FMVSS and affix a label certifying that the vehicle complies.

I have enclosed a copy of an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. It identifies relevant Federal statutes and this agency's standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. It also explains how to obtain this agency's safety standards and regulations. If you have further questions we shall be pleased to answer them.

ID: nht94-2.6

TYPE: Interpretation-NHTSA

DATE: March 29, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom Delapp -- Executive Coach Builders, Inc. (Springfield, MO)

TITLE: None

ATTACHMT: Attached to undated letter from Tom Delapp to Chief Council, NHTSA (OCC 8868)

TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, "Door locks and door retention components," as it pertains to the locking mechanism of a so-called "5th" door installed on your limousines . I apologize for the delay in responding. We conclude that the locking mechanism on the 5th door is not prohibited by Standard 206.

Based on your letter and a conversation with David Elias of my office, I understand that you have replaced the extra panel on the right side of a 1993 Lincoln Town Car based limousine with a passenger door (i.e., the 5th door). The door consists complete ly of the original equipment manufacturer's materials and hinges. The 5th door is a supplementary door, and does not replace or effect in any way the two side rear doors with which your vehicles are normally equipped.

When the 5th door is closed, its locking mechanism engages automatically, and the door cannot be opened from the inside or the outside. A solenoid locking mechanism that unlocks the 5th door is located inside the vehicle in a "privacy panel" behind the driver's seat. For the driver to unlock the 5th door, the car must be stopped and the driver must then get out of the car and reach through a window into the area behind the driver's seat. The locking mechanism cannot be reached by the driver while sea ted in the driver's seat, and cannot be reached by the passengers in the rear seats. The 5th door cannot be accidentally opened; unless the locking mechanism has been actively disengaged, the door remains locked. Disengaging the locking mechanism for t he 5th door allows the driver to open the door from the outside, although passengers could push the door open from the inside, as well.

There are two pertinent requirements of FMVSS No. 206 to your situation. First, S4.1.3 (Door Locks) states that:

Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.

In two prior letters, to Mr. Charles Murphy on May 10, 1974, and to Mr. Gary Hackett on April 11, 1988, the agency interpreted S4.1.3 to mean that the locking mechanism must also be OPERABLE from within the vehicle.

The first question to be addressed is whether the 5th door meets the requirement of S4.1.3. We believe the answer is yes, the door is equipped with a locking mechanism with an operating means in the interior of the vehicle that is operable from within the vehicle. The operating means for the locking mechanism is in the interior of the vehicle in that the locking mechanism engages automatically when the 5th door is closed. While the means to

disengage the operating mechanism is not accessible to occupants in the vehicle, Standard 206 does not require the locking mechanism to be capable of being disengaged by an occupant. This is because the purpose of the standard is to minimize the chance that occupants of the vehicle will be ejected in a collision. Thus, the thrust of the standard is to ensure that occupants are retained within the vehicle, such as by requiring doors to have door locks that occupants are capable of locking.

The second pertinent requirement is S4.1.3.2 (Side Rear Door Locks), which states that:

... when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.

The 5th door appears to comply with S4.1.3.2, in that it cannot be opened from the outside or inside when the locking mechanism is engaged.

In a letter to Ms. C.D. Black, dated April 10, 1987, the agency interpreted a question on child safety locks that is relevant to your situation. The child safety lock operated as a "secondary locking system" that, when activated, rendered the inside rea r door handle incapable of opening the door. (It had no effect on the outside door handle.) As we stated in that letter, our conclusion was that Standard 206 permitted the child safety lock because the standard prohibits only secondary locking systems that interfere with the ENGAGEMENT, but not with the DISENGAGEMENT, of the primary locking system. In that letter, we wrote:

The answer to your question about the child locking systems is dependent on whether the systems interfere with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of... S4.1.3.2 are written in terms of what must occur when the primary system is engaged and impose no requirements regarding the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of ENGAGING the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door hand les be inoperative when the locking mechanism is ENGAGED. Since we have determined that... S4.1.3.2 do(es) not address the effects of disengaging the required door locks--i.e., S4.1.3.2 does not require that the inside rear door handles b e operative (capable of releasing the door latch) when the required locking system is disengaged--a child locking system may be provided on a vehicle if it does not negate the capability of the door lock plunger (the operating means) to engage the door locks.

I hope this information has been helpful. If you have any further questions, feel free to contact Mr. Elias at the above address or by phone at (202)366- 2992.

ID: nht94-2.60

TYPE: Interpretation-NHTSA

DATE: April 26, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Michael E. Klima -- Managing Engineer, Failure Analysis Associates, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 3/29/94 from Michael E. Klima to Edward Jettner (OCC-9832)

TEXT:

This responds to your letter of March 29, 1994, to Mr. Edward Jettner of this agency concerning the dynamic testing requirements of Standard No. 208, Occupant Crash Protection. Your questions concern the application of this standard to a pickup truck ma nufactured in April 1988 with a gross vehicle weight rating (GVWR) of 4,400 pounds. You asked whether the injury criteria in S6 apply to this truck, whether a 35 mph fixed barrier crash test is required, and which sections of Standard No. 208 apply to t his truck.

The safety belt installation requirements for all vehicle types are set forth in Standard No. 208. Section S4.2.1 of standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in trucks and multipurpos e passenger vehicles with a GVWR of 10,000 pounds or less, manufactured on or after January 1, 1976 and before September 1, 1991. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seati ng positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protectio n requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic prot ection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3, requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system f or those belts.

According to your letter, the manufacturer installed Type 2 seat belt assemblies at the front outboard seating positions. This suggests that the manufacturer chose to comply with Option 3. Under this option, the only requirements in Standard No. 208 th at those belts were required to comply with were S7.1, S7.2, and S7.3. The belts were also required to comply with the requirements of Standard No. 209, Seat Belt Assemblies. The manufacturer was not required to certify that the vehicle complied with t he dynamic testing requirements of Standard No. 208. The injury criteria in S6 of the standard are applicable only to vehicles which must comply with the dynamic testing requirements.

Standards No. 208 does not include a 35 mph fixed barrier crash test requirement. The dynamic crash test in Standard No. 208 is barrier crash test at any speed up to 30 mph. NHTSA does perform some 35 mph barrier

crash tests as part of the New Car Assessment Program (NCAP). NCAP is a consumer information program, not a safety compliance test. NHTSA does not test every vehicle under this program. In the 1993 model year program, NHTSA tested 37 new vehicles and released results on 68 additional vehicles which had been tested previously and had not changed significantly in model year 1993.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht94-2.61

TYPE: INTERPRETATION-NHTSA

DATE: April 27, 1994

FROM: DEAN LAKHANI -- PRESIDENT, GEM MANUFACTURING CORPORATION

TO: OFFICE OF CHIEF COUNSEL -- NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 8/3/94 from John Womack to Dean Lakhani (Std. 208)

TEXT: Dear Counselor,

Our company has been in business will over 50 years, manufacturing bumper guards for the passenger car, pickup truck and van industry. These products are used in our country and sometimes exported abroad. These products have over the years saved lot s of lives and a lot of money spent towards costs resulting out of collision damage.

There were several competitors in the days when all the auto vehicles had metal and five mile per hour crash bumpers. Now, it appears that (and we have been told by Ford and General Motors) we are the only bumper guard manufacturing company left in a ll the U.S. All the other bumper guards manufacturers have closed down because of lack of market for bumper guards.

Our primary market disappeared when the 2 1/2 mile collapsible plastic or fiberglass bumpers were approved. Now with the introduction of the air bags (Federal Motor Vehicle Standard # 208), our taxi-cab and police car markets are drying up.

General Motors and other auto manufacturers, it appears have advised consumers, taxi-cab and police fleet administrations that if a bumper guard or any other similar device is placed in front of the bumper, it would interfere with # 208 device (the ai r bag) and the car manufacturers guarantees or warranties would then be questionable. This has caused the consumers, taxi-cab and police car administrators enough concern so as to stop buying bumper guards from us. This has caused the taxi-cab bumper g uard market and the police car bumper guard market to reduce substantially and it is now literally drying up. We may be forced soon to close our doors.

2

We need your prompt assistance, your unequivocal opinion on the issue of whether the attachment of a bumper guard to the front bumper of a vehicle will interfere with Federal Motor Vehicle Standard # 208 devise (air bag device).

Sir/Madam, in our company, except for three employees, the next junior most employee has been with the company for 17 years and the 2 senior most employees have been with the business 43 years and 47 years, respectfully. By closing this business, bel ieve me, we will lose hands-on knowledge and talent that has been the backbone of our country's industrial might!

Please do help us. We are all praying for your prompt response.

ID: nht94-2.62

TYPE: InterpretationNHTSA

DATE: April 28, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Mark M. McGregor

TITLE: None

ATTACHMT: Attached to letter dated 3/31/94 from Mark M. McGregor to Office of Chief Council, NHTSA (OCC-9847)

TEXT:

This is in reply to your letter of March 31, 1994, with respect to Federal regulations that may apply to a motor vehicle rear lighting device that you have invented.

Your "Safe Driving Indicator Light," mounted on the rear of a vehicle, would emit one color ("possibly green") which would change to red when a vehicle following came too close.

To put it at its simplest, an invention such as yours is permissible under the Federal statutes and regulations of this agency as long as it does not negatively affect the performance of the lighting equipment that is required by Federal Motor Vehicle Sa fety Standard No. 108 Lamps, Reflective Devices and Associated Equipment. This is the Federal standard that specifies what is required as original lighting equipment on motor vehicles.

More specifically, paragraph S5.1.3 of Standard No. 108 permits non- required lighting devices as original equipment if it does not impair the effectiveness of the required lighting equipment. We believe that your invention, as described, has the potent iality to impair the stop lamp system. While running lamps of the color red are permitted (e.g. taillamps), the sudden change from green to red of the lamp of your system could be misinterpreted as a signal to the car following that the car ahead is pre paring to stop. However, the purpose of your lamp is not to indicate a stop but to warn the following driver that (s)he is too close.

As a warning lamp, we believe that your use of amber as a color, rather than red, would convey the desired message without impairing the effec- tiveness of the stop lamps. But you should consider the intensity and location of the lamps to avoid impairme nt of the rear turn signal lamps.

With respect to the aftermarket, 15 U.S.C. 1397(a)(2)(A) (Section 108(a)(20)(A) of the National Traffic and Motor Vehicle Safety Act) prohibits a manufacturer, dealer, distributor, or motor vehicle repair business from knowingly rendering inoperative in whole or in part any device or element of design installed in accordance with a Federal motor vehicle safety standard. We interpret this as not forbidding activities by persons other than those named above that affect the compliance of a vehicle with th e Federal safety standards. Thus, the installation of your invention emitting a red color is not precluded if the invention is intended for installation by a vehicle owner, and is not prohibited for installation by others if the warning light color is a mber.

However, you must still determine whether use of the lamp is permissible under the laws of States where it will be used. We are unable to advise you on State laws and suggest that you write for an opinion to: American Association of Motor Vehicle Admin istrators, 4600 Wilson Boulevard, Arlington, VA. 22203.

ID: nht94-2.63

TYPE: INTERPRETATION-NHTSA

DATE: April 29, 1994

FROM: William L. Blake

TO: United States Department Of Transportation

TITLE: Re: 1985 Mercedes Benz, Model 280SL, Seriel NO. WDB1070421A026883

ATTACHMT: Attached To Letter Dated 6/9/94 From John Womack to William L. Blake (A42; PART 581; 591; CSA 5106) And Letter Dated 5/11/94 From William Blake To U.S. DOT

TEXT: Gentlemen:

Please be advised that I represent the owner of the foregoing vehicle. I am advised that this vehicle was manufactured and assembled in Europe and shipped to the United States, modified slightly, and then sold. Modification did not include removal o f, or modification of, bumpers to conform to United States crash standards.

The bumper of this vehicle has now been damaged. My client placed a claim with his insurance company, and the insurance company insists that the vehicle can be repaired with parts which were allegedly illegally imported. The reputable body shop to w hich my client took the vehicle indicates that it is illegal to import bumper parts which do not conform to United States crash standards and that accordingly the entire bumper must be replaced in order to conform to United States safety standards.

Please advise as to the following:

1. As to whether it is or is not illegal to import European bumper parts for these so-called gray model vehicles.

2. As to whether it is or is not illegal for an owner to participate in the installation of bumper parts which do not conform to United States standards.

2

Please refer me to the appropriate statutes and/or regulations relative to the foregoing.

Thank you very much for your cooperation.

Yours very truly,

ID: nht94-2.64

TYPE: INTERPRETATION-NHTSA

DATE: May 2, 1994

FROM: Paul L. Anderson -- President, Van-Con Inc.

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: Re: Items Applicable To Type A-1 School Buses Under 10,000 Lbs. Gross Vehicle Weight In New 217 FMVSS.

ATTACHMT: Attached To Letter Dated 5/18/94 From John Womack To Paul Anderson (A42; Std. 217)

TEXT: Dear Mr. Womack:

Please advis us of the items applicable to Small School Buses, Sixteen & Twenty Passenger, less than 10,000 lbs. Gross Vehicle Weight pertinent to the new 217 FMVSS.

We were told earlier by Mr. Charles Hott that the reflective marking tape outlining Rear Emergency Doors was not required on Type A-1 School Buses.

Please tell us if Type A-1 School Buses need the following items:

1. Roof Hatches ? 2. Push Out Windows on each side ? 3. Reflective Marking Tape around Emergency Rear Doors ?

We received a notice today that the new standard 217 will not become effective until September 1, 1994 and that it only applys to School Buses with capacity of 24 to 90 passengers.

Very truly yours,

ID: nht94-2.65

TYPE: Interpretation-NHTSA

DATE: May 3, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Peter Drymalski -- Investigator, Montgomery County Government, Office of Consumer Affairs

TITLE: None

ATTACHMT: Attached to letter dated 3/1/93 from Peter Drymalski to John Womack (OCC-8371)

TEXT:

This responds to your letter and telephone conversations with David Elias, formerly of this office, asking about a situation you term as the "cannibalization" of new, unsold vehicles. I apologize for the delay in our response.

The situation involves motor vehicle dealers who remove equipment (e.g., a power steering pump) from new vehicles to repair or replace malfunctioning equipment on previously-sold vehicles. The new vehicles are "cannibalized" to expedite repairs when rep lacement equipment for the repair is temporarily unavailable. The new vehicles have their cannibalized equipment replaced when the parts become available, before the vehicles are sold.

You ask whether the National Highway Traffic Safety Administration (NHTSA) permits dealers to cannibalize parts. As explained below, the answer is yes, provided that certain requirements are met.

By way of background, the National Traffic and Motor Vehicle Safety Act ("Safety Act") authorizes NHTSA to issue Federal motor vehicle safety standards ("FMVSS's) applicable to new motor vehicles and items of motor vehicle equipment. Section 108(a)(1)(A ) of the Safety Act prohibits any person from manufacturing or selling a new vehicle manufactured on or after the effective date of any applicable FMVSS that does not comply with each of those standards. Under S114 of the Safety Act, each motor vehicle must be certified as conforming to the FMVSS's. NHTSA's certification regulations (49 CFR Part 567) require any person altering (i.e., performing extensive manufacturing operations on) a certified vehicle before the first purchase of the vehicle by the consumer to certify that the vehicle, as altered, conforms to all applicable standards affected by the alteration. 49 CFR S567.7. However, persons altering a certified vehicle only by the addition, substitution, or removal of "readily attachable compone nts" (e.g., mirrors or tires and rim assemblies) or by performing minor finishing operations (e.g., painting), are not considered alterers, and need not re- certify the vehicle.

Whether modifications involve "readily attachable" components depends on the intricacy of the installation of those components. "Simple tools, a relatively short installation time, and the ability to install the device without extensively modifying the vehicle would all be factors pointing to a decision that a component is readily attachable." NHTSA letter to Fred Cords, March 4, 1975. Applying these considerations to the situation you present, we conclude that a power steering pump is a readily atta chable component.

A power steering pump can be installed with extraordinary ease. The pump can be replaced on the dealer's lot in minutes, simply by opening the hood and popping the old pump out and inserting the new one, with no need to use special tools or have special expertise. The pump can be replaced without extensively modifying the vehicle in any manner.

Since the power steering pump is a readily attachable component, the dealer described in your letter is not an alterer under S567.7. The dealer can "cannibalize" the new unsold cars for power steering pumps and install new pumps when they arrive without applying its own new certification label.

I emphasize that a dealer would not be considered an alterer only in the narrow circumstances in which the component being "cannibalized" is readily attachable. If the component is not readily attachable, the dealer could "cannibalize" the new cars and later repair and sell them if the following requirements are met. First, the dealer would be responsible under S108(a)(1)(A) of the Safety Act for ensuring that each new vehicle it sells complies with the applicable FMVSS's. Thus, the new vehicle must comply with the FMVSS's. Second, the dealer would be responsible, as an "alterer," for certifying the new vehicles from which it removed and replaced the equipment. The dealer would be an alterer since the work performed would be more extensive than "t he addition, substitution, or removal of readily attachable components" or the "minor finishing operations" described in S567.7. The dealer would certify the vehicle by allowing the original certification label of the type and form specified in S567.7.

In all cases, including where the dealer is replacing a readily attachable component, the dealer must also adhere to S108(a)(2)(A) of the Safety Act, which provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an appli cable Federal motor vehicle safety standard, unless such manufacturer, distributor, dealer, or repair business reasonably believes that such vehicle or item of equipment will not be used... during the time such device or element of design is rendered ino perative.

The effect of S108(a)(2)(A) is to limit the modifications that a dealer may make to a new or used vehicle. If, in making the temporary repair affecting a new vehicle, the dealer "renders inoperative" a device or design installed on the new vehicle pursu ant to an FMVSS, the dealer must return the vehicle to compliance before the new vehicle can be sold to the public, or even test-driven by a member of the public.

Section 108(a)(2)(A) also applies to the used vehicles into which the cannibalized equipment is installed. The dealer must ensure that it does not violate the Safety Act by "rendering inoperative" equipment or designs on the vehicles in the process of r epairing them.

I hope this information has been helpful. If you have any further questions, please contact Deirdre Fujita of my staff at this address or

by phone at (202) 366-2992.

ID: nht94-2.66

TYPE: Interpretation-NHTSA

DATE: May 4, 1994

FROM: Richard Kreutziger -- Executive Director, New York State Distributors Ass'n. (OCC-9945)

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/18/94 from John Womack to Richard Kreutziger (A42; Std. 217)

TEXT:

I have today received the preliminary data from one of the members of NYSBDA the following "fax".

As noted in the preliminary data of FMVSS 217 - there are a number of bus body distributors. As also noted these are small business operations and many, many things affect their ability to carry on a successful company profitable operation. Among the " things" is keeping current with the "school bus regulations". In the process of their daily business - the sales and pricing of their vehicles to comply with the requirements of state and federal regulations and standards is very important. I hope you are readily able to realize the point I am trying to make. Quick changes can be very detrimental to that profit factor as well as the individual position of accountability to, not only their customers - but to themselves.

As you can readily view from the following "fax" there are certain "conditions" that are acceptable to the manufacturer.

We have a special position here in New York State - in that the state regulations exceed the minimum 217 requirements (except for placement of left side emergency door). NYS requires added emergency exits, such as push-out windows and roof hatches based upon capacity of the vehicle.

The distributors now are faced here in New York State with a very large unknown factor. To meet the state regulations - for door (L/S/E/D) placement - with folding seat cushion - longer body length - aisle dimension factor at L/S/E/D. Anything that you can furnish and supply to me in a timely fashion - to help my association membership will be greatly appreciated.

Attachment

CARPENTER MANUFACTURING, INC.

BULLETIN NO. 94 - 34 May 3, 1994

TO: All Carpenter Distributors

SUBJECT: EMERGENCY EXIT - DELAYED EFFECTIVE DATE

NHTSA has postponed enactment of certain parts of FMVSS 217 relative to emergency exits; this change was to have taken effect on May 2, 1994. We were notified by fax on May 2nd that the effective date of the "additional emergency exit" requirement "has been delayed until September 1, 1994."

Carpenter will allow its distributors to omit certain options on orders currently in-house at no change order fee, provided the following conditions are met:

1. Order is not on schedule or started at time of receipt of change order; 2. Change order must be received by Friday, 5/13/94; 3. Only options on list below can be deleted or changed; 4. No pre-built orders can be changed; 5. Body length change will require cancellation of current order and resubmission of new order at current pricing.

Approved option deletions are:

1. Side emergency door and related components; 2. Flip seats and 4-logged seats; 3. Heater plumbing and routing; 4. Roof hatches and push-out sash not required by state specs.

Please note that the rear door hold-open device and reflective striping around the rear door opening will still be required and cannot be deleted.

You must keep in mind that orders are being schedule constantly; therefore, it is important to get any change order faxed as soon as possible. You will be notified by Martin Miller as to whether or not your change order can be accepted.

You may cover more than one body order on each change order, but all bodies on a given change order must have identical changes.

Todd Bontrager Asst. Vice President of Sales School Bus Division

ID: nht94-2.67

TYPE: Interpretation-NHTSA

DATE: May 5, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tilman Spingler -- Robert Bosch GmbH

TITLE: None

ATTACHMT: Attached to letter dated 3/25/94 from Tilman Spingler to John Womack (OCC-9889)

TEXT:

This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems.

You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerni ng indivisibility and integration...."

There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design.