ID: nht94-6.23

DATE: April 19, 1994

FROM: S. Greiff -- PARS, Passive Ruckhaltesysteme GmbH

TO: Chief Counsel -- US Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To S. Greiff (A42; Std. 208)

TEXT: Per Fax: 001/202-366-3820

Your "Laboratory Test Procedure For FMVSS 208/212/219/301"

Gentleman:

PARS is a company developing occupant restraint systems for the world wide automotive industry. One of our major topics is the development of airbag systems.

For development and validation of the restraint systems we own a Barrier Impact Test Facility which was built up in 1993 new.

Our runway is 80 m (260 feet's) long. The velocity tolerance up to 60 kph is +/- 0.1 kph.

In your Laboratory Test Procedure for FMVSS testing, a minimum runway length of 500 feet is requested.

We would like to ask you for an interpretation of your "500 feet requirement".

It would be much appreciated, if we could get an answer by fax.

Our fax no. is: 01149/6023/942-133

Thank you very much for your efforts in advance.

Sincerely yours

ID: nht94-6.24

DATE: April 18, 1994

FROM: Mike Parker -- Member of Congress, House of Representatives

TO: Christopher Hart -- Acting Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/31/94 from John Womack to Mike Parker (A42; Std. 222; Part 571.3), letter dated 1/31/94 from Steve Williams to William Moss, and letter dated 1/28/94 from Steve Williams to Terry L. Voy

TEXT:

I have been contacted by Mr. George Duke of the Jones County School District who is seeking to install four nine inch television monitors in a school bus in order to air drug-free videos. The school district has already purchased the equipment but has been told by the state department of transportation that they must receive approval by the NHTSA. Please provide me suggestions and information which I can share with Mr. Duke to assist him with this endeavor.

Thank you for your time and attention to this matter. I look forward to hearing from you.

ID: nht94-6.25

DATE: April 18, 1994

FROM: Fred Benford -- 100+ Motoring Accessories

TO: John Womack -- Acting Chief Counsel, NHTSA

COPYEE: Russ Fuller; Everett Fuller; Cliff Cook

TITLE: None

ATTACHMT: Attached To Letter Dated 5/16/94 From John Womack To Fred Benford (A42; Std. 211)

TEXT: Dear Mr. Womac:

The Chief Counsel of the Specialty Equipment Manufacturers Association (SEMA) reviewed all regulations covering wheel covers and suggested that we contact Mr. Truman Vincent. We explained our situation to Mr. Vincent who in turn, suggested that we address our request to your attention.

We are a manufacturer of Aluminum Wheel Covers. They are a standard type and do not have any protrusions (e.g., spinners, etc.). With the assistance of the Chief Counsel at SEMA, the current regulations were reviewed and it was determined that our Aluminum Wheel Covers are similar in design to the Steel and ABS plastic type and are not covered by any regulations, except for # 211 which prohibits protruding objects such as spinners, etc. Our wheel covers do not have any protruding objects.

At the current time, we are the only manufacturers of Aluminum Wheel Covers. Because they are made of a different material from the current steel and ABS models, a major retailer has asked us to confirm that aluminum, like the ABS and Steel wheel covers, do not violate any federal safety standards. Considering information from our SEMA counsel, and Mr. Truman Vincent, we do indeed not violate any federal safety standards. However, the major retailer (and possibly others) has requested a confirmation in writing from the Department of Transportation. We would appreciate a statement from you with wording to this effect to present to the retailer.

Thank you for your assistance. We would appreciate hearing from you quickly. If desired, you may fax your response to the phone listed below.

Sincerely,

ID: nht94-6.26

DATE: April 18, 1994

FROM: Robin Liu -- President, Introbusy

TO: Stephen Wood -- Transportation Department, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 6/6/94 From John Womack To Robin Liu (A42; Std. 108; VSA 108(a)(2)A)

TEXT: DEAR MR. WOOD:

WE ARE GOING TO IMPORT A MERCHANDISE OF STOPPING LAMP FOR AUTOMOBILES. ITS FEATURE AND USAGE ARE AS PER THE ATTACHED SHEETS/PHOTOS.

WE WOULD LIKE TO KNOW WHETHER IT MEETS THE REGULATION OF YOUR DEPARTMENT BEFORE WE PLACE ORDERS FOR IMPORTATION.

DO WE NEED TO GET ANY OFFICIAL APPROVAL OR TO APPLY ANY LICENSE TO ENSURE THAT INSTALLING THIS PRODUCT IN MOTOR VEHICLE WILL NOT VIOLATE THE REGULATION OF TRANSPORTATION DEPARTMENT?

SHOULD YOU NEED FURTHER DETAILS OR CLARIFICATION, PLEASE EITHER WRITE TO US AT THE ADDRESS UNDERNEATH OR CALL/FAX TO US AT (415) 468-3831.

WE LOOK FORWARD TO HEARING FROM YOU SOON.

SINCERELY YOURS

ID: nht94-6.27

DATE: April 18, 1994

FROM: John Collins -- Senior Vice President, Government Affairs, American Trucking Associations (Alexandria, VA)

TO: John G. Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9/2/94 from John Womack to John Collins (A42; Std. 121)

TEXT:

This letter is a request for an interpretation of the test procedure specified in paragraph S5.8.2, "Supply line retention", of Federal Motor Vehicle Safety Standard (FMVSS) 121, "Air Brake Systems". The last sentence in this paragraph states:

"A trailer shall meet the above supply line retention requirement with its brake system connected to the trailer test rig shown in Figure 1, with the reservoirs of the trailer and test rig initially pressurized to 100 psi, and the regulator of the test rig set at 100 psi."

Our interpretation of test conditions specified in this sentence and Figure 1 (copy attached) is that:

1. The test rig remains connected to the shop air, as shown in Figure 1, for the duration of the test.

2. The shut-off valve of the test rig remains open for the duration of the test.

3. The pressure in the test rig's 1000 cu in. reservoir is maintained at 100 psi for the duration of the test.

The basis for our interpretation are:

a. S5.8.2 does not say that the test rig is to be separated from the shop air supply for the test.

b. S5.8.2 does not say to turn the shut-off valve to the "off" position for the tests. The valve is considered to be normally "open" for tests since it is "open" during the tests for which the test rig was originally designed (brake apply and releasing timing tests in paragraphs S5.3.3 and S5.3.4 of FMVSS 121) and these paragraphs do not say to have the shut-off valve "open" the tests.

c. There would be no reason for S5.8.2 to specify setting the regulator valve at 100 psi if air was not flowing through the regulator valve. Air can only flow through the valve in this test when air is coming from the shop air supply and going out through the shut-off valve.

d. When a combination vehicle is moving, the vehicle's air compressor is operating to maintain the air system pressure within a specified range.

Whenever the trailer supply line pressure is less than the tractor reservoir pressure, air is flowing through the supply line.

We would very much appreciate an early answer to this request as The Maintenance Council of the American Trucking Associations is planning tractor- trailer air systems tests during the first week of May. The objective of these tests is to develop information which will help manufacturers and owners build/modify equipment in such a way as to effectively live with the requirements of S5.8.2 as we interpret the.

Attachment

Figure 1. - Trailer Test Rig. (Graphics omitted.)

ID: nht94-6.28

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Robert L. Montgomery -- Safety Manager, Leprino Transportation Division, Leprino Foods (Denver, CO)

TITLE: None

ATTACHMT: Attached to letter dated 3/24/94 from Marvin A. Leach to Robert Hellmuth (OCC 9821); Also attached to letter dated 3/24/94 from Marvin A. Leach to to Robert L. Montgomery; Also attached to a letter dated 3/9/94 from Robert Montgomery to Mike Baker

TEXT:

This replies to your letter of March 9, 1994, to the Regional Office of the Federal Highway Administration (FHWA). You have questions regarding the trailer conspicuity requirements of Federal Motor Vehicle Safety Standard No. 108, a regulation of the National Highway Traffic Safety Administration.

You have enclosed photos of two rear end treatments. In Photo #1, the conspicuity treatment is applied "on the doors at a height of 56 inches which is approximately 6 inches higher than the 1.25 meters (50 inches) dictated." The conspicuity treatment appears to extend the full width of the vehicle. In Photo #2, the reflectorized material is located "4 inches less than the 1.25 meters (50 inches) dictated." In this configuration, the conspicuity treatment has been relocated to a position between the rear lighting units so that it no longer extends the full width of the vehicle.

Photo #1 represents the trailer as received from the manufacturer. Photo #2 represents the modifications you wish to make to the trailer. You have asked whether the configuration depicted in Photo #2 complies with Standard No. 108.

The manufacturer of the trailer has certified its compliance with all applicable Federal motor vehicle safety standards, including the conspicuity treatment location requirements of Standard No. 108. Paragraph S5.7.1.4.1(a) specifies that the material be located "as close to the extreme edges as practicable." The relocation you contemplate would place the material where it is not as close to the extreme edges of the trailer as it originally was. This would create a noncompliance with Standard No. 108.

Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(20(A)) (the Act) prohibits any 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. The prohibition, however, does not apply to the vehicle owner. This means that Leprino Foods and its employees are not themselves prohibited by the Act from modifying your trailers to the configuration depicted in Photo #2. It does mean that a "manufacturer, dealer, distributor, or motor vehicle repair business" cannot perform this work for you.

We surmise that your trailers are subject to the jurisdiction of the FHWA when they are operated in interstate commerce. FHWA regulations require your trailer to be equipped to conform to Standard No. 108. Thus, if you modify your trailers so that they no longer conform to the rear location requirements of

Standard No. 108, you would be in violation of the regulations of that agency. This is to advise you that the FHWA has concurred in this interpretation to you.

Either mounting height location is permitted. Originally, Standard No. 108 did specify a mounting height for rear conspicuity material that was "as close as practicable to 1.25 meters above the road surface." However, the agency amended this paragraph on October 6, 1993, to adopt a height range of "as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface." This is the equivalent of 15 to 60 inches above the road surface. Therefore, the mounting heights of 46 and 56 inches shown in your two photos is in accordance with the revised requirement.

Finally, we note your comment that the diagram in the Federal Register "failed to consider the bumper bar area and the light assemblies that are actually on a van." The requirements that must be adhered to are found in the text of Standard No. 108; Figure 30 is meant only as a general guide as to the placement of the conspicuity material. Obviously, it cannot depict the exact rear configuration of all van trailers.

ID: nht94-6.29

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TITLE: None

ATTACHMT: Attached to letter dated 1/6/94 from Thomas D. Turner to John Womack (OCC 9549); Also attached to letter dated 3/9/77 from Frank A. Berndt to W.G. Milby (Std. 217)

TEXT:

This responds to your letter of January 6, 1994, asking several questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413; November 2, 1992). Our response to each of your questions follows.

1. Your first question requested confirmation that a left side emergency exit door required by S5.2.3.1(a)(2)(i) would meet the location requirements of S5.2.3.1(a)(2)(i) if it is located in the center one-half of the passenger compartment.

Your question concerns the first required additional emergency exit installed on a bus with a rear emergency exit door. Section S5.2.3.2(a)(2) requires this exit to be a side emergency exit door "located on the left side of the bus and as near as practicable to the midpoint of the passenger compartment." Locating the door or the 12-inch required aisle opening for the door in the center one-half of the passenger compartment would not ensure compliance with this requirement. This is because it may be possible to locate a door in the center one-half without locating the exit "as near as practicable to the midpoint of the passenger compartment." In determining the permissible location for this exit, you should determine where the exit would be located if it was located at the midpoint of the passenger compartment. If it is not practicable to locate the exit there, you should move the door only as far as necessary for a practicable location.

2. Your second question requested confirmation that there are no fore and aft location requirements for side emergency exit doors other than the requirements for a left side emergency exit door required by S5.2.3.1(a)(2) (i).

You are correct. Except for a left side emergency exit door installed as the first additional emergency exit on a bus with a rear emergency door, the only location requirements for side emergency exit doors concern the side of the bus on which the exit must be located. I have attached for your information an appendix which lists all the location requirements for additional emergency exits.

3. Your third question requested confirmation that all side emergency exit doors, including any voluntarily installed, are required to comply with the requirements of the new final rule, including the seat placement requirements in S5.4.2.1(b).

You are correct. Your letter referred to a March 9, 1977 interpretation that voluntarily installed side emergency exit doors were not required to meet the school bus requirements, but were required to meet the non-school bus requirements. Previously, the school bus emergency exit door requirements in Standard No. 217 referred to "the emergency door." At that time school buses were required to have either one rear emergency exit door or one side emergency exit door and one rear push-out window. Thus, any school bus was required to have only one emergency exit door. The reference to "the emergency door" was to the required door.

In the recent amendments to Standard No. 217, some of the performance requirements for emergency exits apply to "each" emergency exit. See, for example, S5.4.2.1(b). This change in the language extends these requirements to any emergency exit door in a school bus. Other requirements apply to "required" emergency exits. See, for example, S5.5.3(c). These requirements do not apply to voluntarily installed emergency exits.

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

APPENDIX

Emergency Exit Location Requirements

In the March 15, 1991, notice of proposed rulemaking to amend Standard No. 217, Bus Emergency Exits and Window Retention and Release, NHTSA proposed very specific location requirements for emergency exits in school buses (56 FR 11153). The agency received comments that many of these locations were not possible or practicable. In response to these comments, the agency concluded that the final rule should include only general requirements for the required exits (57 FR 49413; November 2, 1992). Therefore, the only location requirements for additional emergency exits (1) included in the final rule were:

o For a bus with a rear emergency exit door, the first additional emergency exit must be an emergency exit door on the left side of the bus and as near as practicable to the midpoint of the passenger compartment (S5.2.3.2(a)(2)).

o For a bus with a side emergency exit door and a rear push-out window, the first additional emergency exit must be an emergency exit door on the right side of the bus (S5.2.3.2(a)(3)).

o If additional emergency exit doors are installed, they must be alternated between the right and left sides of the bus (S5.2.3.2(a)(2) and (3)).

o No two emergency exit doors may be located in the same post and roof bow panel space (S5.2.3.2(a)(4)).

o If one emergency roof exit is installed, it must be located as near as practicable to the mid-point of the passenger compartment (S5.2.3.2(b)(2)).

o If two emergency roof exits are installed, they must be located as near as practicable to a point equidistant from the midpoints of the passenger compartment and either the front or rear of the passenger compartment (S5.2.3.2(b)(3)).

o If three or more emergency roof exits are installed, the space between each exit shall, to the extent possible, be the same or equal to the space between the front (or rear) limit of the passenger compartment and the front (or rear) roof exit (S5.2.3.2(b)(4)).

o Emergency roof exits must be installed so that their longitudinal centerline coincides with the longitudinal centerline of the bus, except that a roof exit may be offset a distance equal to the distance another roof exit is offset in the opposite direction (S5.2.3.2(b)(5) and (6)).

o Emergency window exits must be evenly divided between the right and left sides of the bus (S5.2.3.2(c)).

(1) The November 2 final rule requires all school buses to have either a rear emergency exit door or a side emergency exit door and a rear push-out window. The rule also requires "additional" emergency exits on buses of specified passenger capacities. "Additional" emergency exits, as the term is used in this appendix, refers to emergency exits other than the rear emergency exit door and side emergency exit door/rear push-out window which Standard No. 217 requires of all school buses.

ID: nht94-6.3

DATE: May 5, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Luis Carricaburu -- South Steering Specialists

TITLE: None

ATTACHMT: Attached To Letter dated 1/1/94 EST From Luis Carricaburu to Mary Versailles (OCC-9613)

TEXT: Dear Mr. Carricaburu:

This responds to your letter asking whether it is legal to buy or sell a salvaged air bag which would be used to repair an automobile with a deployed air bag. Your letter explained that the salvaged air bag would be taken from an automobile sent to a recycling yard with its air bag intact.

I am enclosing two letters that explain legal obligations to replace air bags which have been deployed. The first letter, dated January, 19, 1990, is to Ms. Linda L. Conrad. The second letter, dated March 4, 1993, is to Mr. Robert A. Ernst. As explained in those letters, Federal law does not require replacement of a deployed air bag in a used vehicle. In addition, there is no Federal law that prohibits selling a used vehicle with an air bag that is inoperable because of a previous deployment. However, our agency strongly encourages dealers and repair businesses to replace deployed air bags whenever vehicles are repaired or resold, to ensure that the vehicles will continue to provide maximum crash protection for occupants. Moreover, a dealer or repair business may be required by state law to replace a deployed air bag, or be liable for failure to do so.

Your letter asks the additional question of whether, if a deployed air bag is replaced, Federal law prohibits use of a salvaged air bag as the replacement air bag. The answer to your question is no. As explained in the enclosed letters, the Safety Act does not require a manufacturer, distributor, dealer, or repair business to return a vehicle to compliance with a standard if a device or element of design has been "rendered inoperative" by another agent, such as a crash. Thus, Federal law does not regulate the manner in which a deployed air bag is replaced. However, state law may regulate the manner in which a deployed air bag is replaced.

I would like to emphasize that in order for a replacement air bag to provide protection to vehicle occupants, it is essential that the replacement be properly completed. For example, the entire air bag must be replaced, including such things as the crash

2

sensors, the inflation mechanism, and other electronic parts. Moreover, since air bags are designed for specific vehicles, taking into consideration such factors as the seats, steering column crush stroke force resistance, gauge array and location on instrument panel, location and nature of knee bolsters, and compartment acceleration responses in frontal crashes, only air bags which are designed for the vehicle in question should be used. After the air bags are replaced, it is important that the air bag readiness indicator be in good working order to alert the occupants of any future malfunction of the air bag system.

While great care must be taken in any air bag replacement, the use of a salvaged air bag raises additional safety issues. An air bag may have been rendered inoperable, for example, by damage in a low-speed crash, even if it has not been deployed. We would urge you to contact the vehicle or air bag manufacturer to determine whether and how a salvaged air bag could be inspected and/or tested to ensure that it is fully operable.

Finally, you may wish to consult a private attorney concerning the state law implications of using salvaged air bags for repairing automobiles, including possible tort liability.

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.

Sincerely,

Enclosures

ID: nht94-6.30

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John Rhein -- Fisher-Price, Inc. (East Aurora, NY)

TITLE: None

ATTACHMT: Attached to letter dated 5/3/93 from John Rhein to John Womack (OCC 8639)

TEXT:

This responds to your letter about the consumer registration card required by Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding.

You ask about three features of a registration card you wish to produce, and enclosed a sample card setting forth a "proposed format." You first ask whether you may specify "Please Print" on the card. The answer is yes. NHTSA interpreted Standard 213 as permitting this feature, in an October 20, 1993 letter to Mr. Richard Glover of the Evenflo Juvenile Furniture Company.

You also ask whether you may use "open box spaces" for the consumer's name and address, to encourage consumers to print the information clearer (one character per box space). The answer is yes. NHTSA interpreted Standard 213 as permitting "blocked squares" for the consumer's name and address in a June 14, 1993 notice (copy enclosed) denying Evenflo's petition for reconsideration of the rule that established the registration card requirement.

Finally, you ask whether you may enlarge the consumer name and address space of the card, to provide consumers more space to print the information and thus increase the likelihood the information will be legible. The answer, with reference to the sample card you provided, is yes. Under S5.8 of Standard 213, the registration form must conform in size, content and format to forms depicted in the standard (figures 9a and 9b). The figures specify a minimum size for the card. Moreover, in the enclosed June 1993 notice, NHTSA explained that "(f)ormat refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material."

The sample card you provided meets the minimum size requirement specified in the standard, and the general appearance and overall organization of the card is the same as that depicted in the standard (figure 9a). While the consumer name and address space is slightly larger than depicted in the standard, we conclude that this slight deviation is consistent with the standard's format requirements. This conclusion is based on the fact that this slight change does not affect the general appearance or overall organization of the card, and because the change provides consumers more space to print the information, i.e., it will not detract from the utility of the card.

Please contact Ms. Deirdre Fujita of my staff at (202) 366-2992 if you have any questions.

ID: nht94-6.31

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John Moore -- Ferrucci Nurseries (Newfield, NJ)

TITLE: None

ATTACHMT: Attached to letter dated 2/4/94 from John Moore to Chief Council, NHTSA (OCC 9645)

TEXT:

This responds to your letter of February 4, 1994, requesting verification of a statement made by a National Highway Traffic Safety Administration (NHTSA) employee that you are allowed to install passenger seats in a van used for farm transportation if you comply with the safety regulations. In a phone conversation with Mary Versailles of my staff, you explained that you would like to add seats to the rear of a 14 foot cargo van which the nursery owns. You would be performing this work yourself. As explained below, Federal law does not apply to situations where vehicle owners alter their own vehicles.

I am pleased to have this opportunity to explain our laws and regulations to you. NHTSA is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.; Safety Act) to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards.

NHTSA has exercised its authority to establish five safety standards which could be relevant to installation of a seat in a used vehicle: Standard No. 207, Seating Systems, Standard No.208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, Standard No. 210, Seat Belt Assembly Anchorages, and Standard No. 302, Flammability of Interior Materials. Standards Nos. 207, 208, 210, and 302 apply, with certain exceptions that are not relevant to your situation, to vehicles and not directly to items of equipment. Standard No. 209, however, applies to seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. Thus, if you install new seat belts on the seats, the manufacturer is required to certify that the seat belts comply with Standard No. 209.

If a seat is installed in a used motor vehicle, the seat, as an item of equipment, does not have to comply with any Federal standards. However, S108 (a)(2)(A) of the Safety Act provides, in pertinent part:

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 applicable Federal motor vehicle safety standard. . . .

None of these entities could install seats in your van if it caused the vehicle to no longer comply with any of the safety standards. Please note, however, that the "render inoperative" prohibition does not apply to modifications vehicle owners make to their own vehicles. Thus, Federal law would not apply in a situation where you as an individual vehicle owner, installed seats in your own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, you should be aware that individual States have the authority to regulate modifications that individual vehicle owners may make to their own vehicles.

While Federal law would not apply to a modification you make to your own vehicle, I nonetheless urge you to exercise care in installing the seats and to install seat belts on the seats. The seats and seat belts will not provide any protection to occupants if they separate from the vehicle frame in a crash. Also, you may wish to consult a private attorney familiar with the law in the State of New Jersey regarding potential liability in tort for your business in these circumstances.

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.