ID: 9325

Mr. John Bloomfield
Manager, Engine Management
Legislation and Certification
Lotus Cars, Ltd.
Hethel, Norwich, Norfolk NR14 8EZ
England

Dear Mr. Bloomfield:

This responds to the letter from Ms. Rachel Jelly, formerly of your company, concerning low volume CAFE exemptions. I apologize for the delay in our response. Ms. Jelly asked whether Bugatti Automobili S.p.A. (Bugatti) and Lotus Cars, Ltd. (Lotus), both of which are controlled by the same holding company, may submit separate low volume CAFE exemption petitions requesting two alternative standards. The answer to this question is no. Since any alternative CAFE standard would apply to Bugatti and Lotus together, a single combined petition must be submitted for a single alternative standard.

The reasons for the above response are discussed in the attached letter from NHTSA to Mr. Lance Tunick, of Bugatti. Mr. Tunick's letter to NHTSA raised issues that are of concern to both Bugatti and Lotus. Thus, NHTSA's response to Mr. Tunick should address Lotus' concerns about filing for alternative CAFE standards.

I hope this information is helpful. If there are any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:525 d:5/9/94

ID: 9326

Mr. J. Z. Peepas
Selecto-Flash, Inc.
P.O. Box 879
Orange, NJ 07051

Dear Mr. Peepas:

This is in reply to your FAX of November 12, 1993, to Taylor Vinson of this Office, the latest in a series of communications about how the conspicuity requirements of Standard No. 108 are to be applied to gooseneck trailers.

On October 20, we sent you a correction of our earlier interpretation of S5.7.1.4.2(a). Our correction stated that the requirement is that conspicuity treatment not be obscured by trailer cargo. If conspicuity treatment is applied to the gooseneck of a container trailer, we understand that it will be obscured by the container (cargo) when it is in place.

S5.7.1.4.2(a) also specifies that conspicuity treatment "need not be continuous as long as not less than half of the length of the trailer is covered and the spaces are distributed as evenly as practicable." The length of the gooseneck is included in determining the overall length of the trailer for purposes of calculating the half length that must be covered by the conspicuity treatment (which, of course, would be greater than half the length behind the gooseneck).

You have suggested that we reevaluate the effect of excluding the gooseneck from compliance with the conspicuity requirements. There is nothing in Standard No. 108 that prohibits a manufacturer from applying retroreflective sheeting to the gooseneck. Indeed, some manufacturers may wish to do so to provide conspicuity of the entire trailer side when the trailer is traveling without its cargo. However, conspicuity treatment on a gooseneck is not counted in determining whether at least half the trailer side is covered. An example may clarify this for you. Let us say that the overall length of the trailer is 40 feet, including an 8-foot gooseneck. The amount of the side to be covered is not less than 20 feet. The area to be covered is the 32 feet between the rear bolster to the point immediately behind the gooseneck's terminus. Thus, regardless of whether conspicuity treatment is applied to the gooseneck, at least 20 feet of this 32-foot length must be covered in order to comply with Standard No. 108, and the spaces must be distributed as evenly as practicable. Standard No. 108 does not address the issue of the length of the spaces between strips, and a manufacturer may choose 4 feet or whatever is feasible for the trailer at hand.

On the basis of this interpretation letter, we believe that Selecto-Flash ought to be able to judge whether the conspicuity treatments on Prints A-1, A-2, B-1 and B-2 accord with Standard No. 108.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:11/30/93

ID: 9327

Mr. Richard L. Plath
Selecto-Flash, Inc.
P.O. Box 879
Orange, NJ 07051

Dear Mr. Plath:

This is in reply to your letter of November 15, 1993, to Taylor Vinson of this Office on trailer conspicuity. You ask for confirmation of several points.

Initially, we would like to comment as follows on the 4-point procedure you have outlined:

"1) A chassis for purposes of the conspicuity requirement shall be considered to be a trailer."

This is correct. Because the chassis is designed for carrying property and for being towed by a motor vehicle, it is a "trailer" as defined for purposes of compliance with the Federal motor vehicle safety standards.

"2) That the total length of the chassis shall be used in computing the 50 percent coverage of high intensity reflective for each individual side."

This is correct. Under S5.7.1.4.2(a) of Standard No. 108, retroreflective tape "need not be continuous as long as not less than half of the length of the trailer is covered . . . ."

"3) In the case of a 48 foot chassis, the law will thus require a minimum of 24 feet of the approved reflective sheeting to be applied to each side. Further, there shall not be more than 18 inches of either red or silver reflective in a continuous strip and that there shall not be an allowed void of more than 48 inches between modules."

This is partially correct. Under S5.7.1.4.2(a), a minimum of 24 feet of reflective material must be applied to the side of a 48-foot trailer. However, S5.7.1.3(a) requires the colors to be red and white, not red and silver. Further, under S5.7.1.3(b), the permissible lengths of the sheeting are expressed as "each white or red segment shall have a length of 300 mm +/- 150 mm." We note that 450 mm is slightly less than 18 inches. Finally, Standard No. 108 does not specify any maximum permissible "void . . . between modules." Under S5.7.1.4.2(a), the spaces are to be distributed "as evenly as practicable."

"4) * * * When the chassis is not loaded with a container, the application of 24 feet per side of a 48 foot chassis of evenly spaced reflective modules would comply with the law as we understand it. It would identify the extreme front and rear portions of the chassis. * * *"

This is incorrect. Compliance by an unloaded container chassis with the conspicuity requirements is determined as if the container load were in place. S7.5.1.4.2(a) states that "at the location chosen [for conspicuity treatment], the strip shall not be obscured in whole or in part by other motor vehicle equipment or trailer cargo." Because the container obscures the gooseneck, the conspicuity treatment mandated by Standard No. 108 cannot identify the extreme front portion of the chassis. Its front termination point will be behind the gooseneck, at a point where it is not obscured by the container. You have correctly stated this with respect to a loaded chassis but it applies to the unloaded chassis as manufactured:

". . . the entire 24 feet (50 per cent of length) [shall] be applied behind the gooseneck. In general this would mean that the rear 40 foot portion of the chassis would contain the 24 feet of reflective modules. Further we understand that the 50 percent requirement would be satisfied and that additional modules would not have to be applied to the gooseneck."

You conclude that a gooseneck chassis traveling without its container would be in violation of Standard No. 108 if its gooseneck were not marked "creating a hazard and would violate the requirement stating that a void of no more than four feet is allowable." You also ask "[i]s there a benefit in applying the additional 4 feet of reflective within the rear 40 foot portion of the chassis?"

As explained previously, Standard No. 108 does not require marking of the gooseneck of a container chassis, and there is no requirement limiting the spacing between segments of retroreflective material. We believe that the desired conspicuity of the trailer will be maintained by requiring the additional 4 feet of sheeting on the chassis behind the gooseneck when the gooseneck itself will be obscured with the container in place. Standard No. 108 does not prohibit a manufacturer from applying conspicuity treatment to the 8-foot gooseneck of a 48 foot trailer if it wishes to do so; however, the manufacturer is still required to apply not less than 24 feet of material in the 40-foot section behind the gooseneck.

We shall be pleased to answer the following four questions you have also raised:

"1) Will we need to apply 24 feet of stripping on a 48 foot chassis behind the gooseneck plus an additional 4 feet on the gooseneck?"

You will have to apply 24 feet of stripping on the portion of a 48-foot chassis that lies behind the gooseneck, but you are not required to mark the gooseneck.

"2) Since a chassis is considered to be treated as a trailer, shouldn't we apply the 24 feet evenly spaced from the extreme rear and front portions of the chassis?"

As explained previously, the 24 feet of material is to be applied behind the gooseneck. If you wish to apply evenly spaced conspicuity treatment that includes the gooseneck, you may do so, as long as at least 24 feet of it is behind the gooseneck.

"3) Is a tire considered a legal obstruction? If so, can we deduct the distance behind the tire from the 50 percent coverage?"

Yes, a tire is "motor vehicle equipment" within the meaning of S5.7.1.4.2(a) forbidding the obscuring of conspicuity treatment. No, you may not deduct the length of the area obscured by the tire from the 50 per cent coverage. You must include it in the 50 per cent computation. Thus, if a tire would obscure 3 feet of conspicuity material on the side of a 48 foot gooseneck trailer, the manufacturer must apply 24 feet of material in the 37 feet that is behind the gooseneck which is not obscured. We note in passing that the prints submitted for our review by J.Z. Peepas of Selecto-Flash depict conspicuity treatment that is above the top of the tire and apparently not obscured by it.

"4) We anticipate that the slide mechanism on an extendable chassis will scrape the reflective film off the chassis. Is the operator then subject to penalties? How will the operator be able to avoid these penalties since they have no control over this process?"

You are not required to place conspicuity treatment on the extendable portion of the chassis provided that not less than half of the length of the trailer is covered when the conspicuity treatment is placed elsewhere. In the event that conspicuity treatment is placed on the extendable portion and is damaged when the trailer is in use, the operator will not be subject to any penalties of this agency. Federal regulations governing the use of commercial vehicles in interstate commerce are issued by another agency of the Department of Transportation, the Federal Highway Administration (FHWA). The FHWA requires that vehicles manufactured on or after March 7, 1989, meet the requirements of Standard No. 108 in effect on the date of manufacture of the vehicle (49 CFR 393.11). Therefore, maintenance of the conspicuity treatment on trailers manufactured on or after December 1, 1993, is required by the FHWA. If you wish to write FHWA on this topic, you may address James E. Scapellato, Director, Office of Motor Carrier Standards, FHWA, Room 3107, 400 Seventh Street, SW, Washington, D.C. 20590.

The individual states may have regulations in this area as well. We are unable to advise you on State requirements, and suggest that you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Blvd., Arlington, Va. 22203.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:11/30/93

ID: 9344

Ms. Kathryn A. Roach
Cooper Perskie April Niedelman
Wagenheim & Levenson
1125 Atlantic Avenue
Atlantic City, NJ 08401-4891

Dear Ms. Roach:

This responds to your letter of November 11, 1993, requesting confirmation of a statement made by a NHTSA engineer that there is no federal regulation that requires replacement of a deployed air bag.

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 a supplemental restraint 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.

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,

John Womack Acting Chief Counsel

Enclosures ref: 208 d:1/10/94

ID: 9345

Cheryl Graham, District Manager
Northeast Region
ARI
P.O. Box 5039
Mt. Laurel, NJ 08054

Dear Ms. Graham:

We have received your letter of November 10, 1993, asking about the permissibility of aftermarket installation of an auxiliary pair of stop lamps "at each side of the rear window."

By way of background information the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards under the authority of the National Traffic and Motor Vehicle Safety Act (Safety Act). Under that Act, the sole restraint upon modifications to vehicles in use is that, if performed by a manufacturer, distributor, dealer, or motor vehicle repair business, the modifications must not "knowingly render inoperative, in whole or in part, any device or element of design installed on . . . a motor vehicle in compliance with an applicable Federal motor vehicle safety standard . . . ." (15 U.S.C. 1397(a)(2)(A)).

In NHTSA's view, if the modifications tend to impair the safety effectiveness of the "device or element of design", then, at the minimum, a partial inoperability may have occurred within the meaning of the statutory prohibition. The question raised by your letter, therefore, is whether the installation of the auxiliary stop lamps in that location would impair the effectiveness of the three original equipment stop lamps.

NHTSA decided to require the center highmounted stop lamp in addition to the then-existing original equipment two-lamp stop lamp system following research which indicated that a three- lamp system of this configuration was demonstrably more effective in preventing rear end crashes than other rear end lighting systems that were tested, and considerably lower in cost. Included in the testing was a four-lamp system which incorporated two lamps at each side of the rear window, but no tests were conducted on the five-lamp system you describe. The reasons for the better performance of the three-lamp system are unclear, but the triangular lighting array proved to be more effective than the trapezoidal four-lamp system (and more effective than a system tested which separated the usual stop lamp from the taillamp).

Your customer appears to believe that the ability of following drivers to avoid rear end crashes is enhanced by a five-lamp stop lamp system. On the other hand, your proposed system, by incorporating the two lamps at each side of the rear window, would appear to change the lighting array. We cannot say that the five-lamp system would either enhance or detract from safety. Thus, we cannot find that the additional lamps would "render inoperative" the original equipment three-lamp system, and it would be permissible under the regulations of this agency. However, the permissibility of such a modification would be determinable under State law. We are unable to advise you on the laws of the various States and suggest that you write the American Association of Motor Vehicle Administrators for an interpretation. Its address is 4600 Wilson Boulevard, Arlington, VA 22203.

You have also asked "if the work is done improperly and results in an accident, where does the liability lie?" This question is a matter of state law, and we suggest that you consult a local attorney concerning it.

Sincerely,

John Womack Acting Chief Counsel

ref:VSA d.2/7/94

ID: 9352

Mr. Andrew Tweddle
AV Technology Corp.
2340 Alger
Troy, MI 48083

Dear Mr. Tweddle:

This responds to your request for an interpretation whether AV Technology's armored vehicle is subject to the Federal Motor Vehicle Safety Standards (FMVSSs). As explained below, a vehicle manufactured to U.S. Army contract specifications, and sold to the Army, is not subject to the FMVSSs.

In your letter, you explained that AV Technology is in the process of responding to a Department of the Army draft specification for an armored security vehicle. AV Technology proposes to offer its Dragoon ASV, an armored security vehicle, with a weapon carrying capability. Your letter states that the Dragoon ASV would be built to U.S. Army specification MIL-STD-1180. In a telephone conversation with Dorothy Nakama of my staff, you stated that the Dragoon ASV would also be built to other applicable military specifications.

The FMVSSs' applicability to vehicles manufactured for and sold to the U.S. military, is addressed at 49 CFR 571.7(c):

(c) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.

You stated the Dragoon ASV would be manufactured to all applicable military specifications, specified by the Army. The Army is part of the "Armed Forces." Thus, when manufactured to Army contractual specifications, and sold to the Army, the Dragoon ASV is not subject to the FMVSSs.

If you have any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel ref:571 d:3/17/94

ID: 9355

Ms. Jane L. Dawson
Specifications Engineer
Thomas Built Buses, Inc.
Post Office Box 2450
1408 Courtesy Road
High Point, NC 27261

Dear Ms Dawson:

This responds to your letter to Walter Myers of this office in which you posed two questions regarding interpretation of certain provisions of Federal Motor Vehicle Safety Standard (FMVSS) 217, Bus Window Retention and Release.

Your first question related to the definition of "daylight opening" found in the final rule amending FMVSS 217, dated November 2, 1992 (57 FR 49413) (hereinafter Final Rule). Specifically, you asked what constitutes an obstruction and how close does it have to be to the exit to be considered an obstruction.

The term "daylight opening" is defined in the Final Rule as "the maximum unobstructed opening of an emergency exit when viewed from a direction perpendicular to the plane of the opening." This refers to the total area of the opening, whether the door or window is open or closed. An obstruction in this context would include any obstacle or object that would block, obscure, or interfere with in any way that opening or any access thereto, as viewed from the middle aisle of the bus. For example, the seatback of a nearby seat that protrudes into the area perpendicular to the plane of the opening would constitute such an obstruction.

In your second question you referred to the current provisions of S5.2.3.1(b), FMVSS 217, which provides that a left-side emergency door must be located in the rear half of the bus passenger compartment. You then asked whether that requirement was changed in the Final Rule. The answer is yes.

S5.2.3.1, as amended in the Final Rule, provides manufacturers two options for the provision of school bus emergency exits, S5.2.3.1(a) (Option A) and S5.2.3.1(b) (Option B). Option A requires a rear emergency door and, in the sequence of choices for providing the additional emergency exit area, the first specifies a left side door that is required by S5.2.3.2(a)(2) to be located at the midpoint of the bus. Option B requires a left-side emergency door and a pushout rear window, but does not designate a specific location for them. Thus, the

locations of exits other than the left side door specified in S5.2.3.1(a)(2)(i) are left to the various design options of the manufacturers and their customers.

I hope this information will be of assistance to you. Should you have any further questions or seek additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief counsel

ref:217 d:4/1/94

ID: nht68-3.18

DATE: 03/12/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: The Reuben H. Donnelley Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 27, 1968, to the Federal Righway Safety Bureau, in regard to obtaining information about Safety Standard No. 209, seat belt assemblies.

Regarding your question on seat belt usage as pertaining to a fire apparatus vehicle, seat belts are not required to be installed, however, if seat belts are installed on a truck by a manufacturer, the seat belt assemblies, as equipment, must meet the requirements of Standard 209, specifically, requirements of the Department of Commerce, National Bureau of Standards for seat belts for use in motor vehicles (15 CFR 9)(30 FR 8432).

Thank you again for your interest in the safety program.

ID: nht68-3.19

DATE: 03/25/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 1, 1967, concerning tests made on the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.

We recognise the validity of a system which takes advantage of the energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing on energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash eltuation. Therefore any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test is specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.

Your second point concerns the need for a more explicit definition of translational motion. SAE J944 states that the body-block contacts the wheel in translational motion. It does not say that this motion must continue after impacting the wheel. Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a stimulation of an actual crash situation and the body-block was not intended by SAE J944 to be restrained in translational motion after impact. Since the body motion in on actual crash situation will very somewhat the Bureau feels that a more explicity definition of translational motion is unnecessary.

The third series of tests as described in Report No. 287.397 using a right test fixture and the free flying body-block are compatible with the SAE J944 test procedure.

Your interest in motor vehicle safety is appreciated.

ID: nht68-3.2

DATE: 02/20/68

FROM: AUTHOR UNAVAILABLE; H.M. Jacklin, Jr; NHTSA

TO: Toyo Kogyo Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 30, 1968 (your reference No. CSAI-25) requesting information to a number of questions related to the Federal Motor Vehicle Safety Standard. I(Illegible Word) that we did not receive your October 5, 1968 letter and that the(Illegible Word) of work has delayed my answer to your most recent letter.

I am glad to send you the following information:

a.(Illegible Word) No. 112 - Headlight Concealment Devices.

1. It is stipulated in 3.4.5 that "each headlamp concealment device shall, within an ambient temperature range of -70 to +120 degrees F., be capable of being fully opened in not(Illegible Line) described in S.4.3." With regard to the temperature condition at the time of a test, if only the(Illegible Word) temperature satisfied the cold temperature conditions, is it all right to try no regard to other conditions, such as the sticking of frost, ice, etc.?

ANSWER: It is only necessary that the ambient temperature conditions (-20 to +120 degrees F.) be(Illegible Word) at the time of the test.

b.(Illegible Word) No. 114 - Thoft Protection.

1. With regard to the regulation in s.4.2 that "The prime cause for deactivating the csr's engine or other main source of motive power shall not activate the(Illegible Word) required by S4.11(b)," we have provided the ignition switch with four stages as shown in the batch below; our key-locking system is of the(Illegible Word) that the system does not activate(Illegible Line)(Illegible Line)

ANSWER: The system as you describe it appears to conform to(Illegible Line)(Illegible Line) with this requirement to the responsibility of the individual manufacturer.

2. With reference to the stipulation in S.4.1. "Each passenger car shall have a key-locking system that, whenever the key is removed, will prevent ----.", we would like to know whether or not we must provide such a mechanism as the key can be removed only at the stage "Lock" and cannot at the stage "Off".

ANSWER: A locking system having such a position that the key may be removed without activating either the cars' steering lock or its self-mobility lock would not conform to the standard in its present form, since paragraph S4.1 of the standard requires each car to have a key locking system that, whenever the key is removed, will prevent either steering or self-mobility of the car, or both.

c. MVSS No. 201 - Occupant Protection in Interior Impact 1. With regard to the interpretation of the stipulation in S.3.1 " , the deceleration of the head form shall not exceed 80 g for more than 3 milliseconds," when the deceleration wave -- shown in the chart below -- is obtained.

in case DELTA t[1] < 3 milliseconds, we interpret that the standard is satisfied even when delta t[1] +="Sigma" t[2] t[3] t[i] milliseconds.

Is our interpretation correct? (Illustration omitted)

ANSWER: Your interpretation is correct. The standard permits more than one peak that exceed 80g which, cumulatively, may add to more than 3 milliseconds. No single peak may continuously exceed 80g for more than a 3 millisecond duration.

2. When the areas stipulated in S.3.1.1.(d) -- "Areas outboard of any point of tangency on the instrument panel of a 6.5 inch diameter head form tangent to an inboard of vertical longitudinal plane tangent to the inboard edge of the steering wheel," -- are illustrated, which of the following hatched portions in the figures below is in conformity to the stipulation? (Illustration omitted)

ANSWER: Figure (a) is correct for the inboard side. Present requirements do not apply to the area outboard of the steering wheel on the instrument panel.

d. MVSS No. 207 - Anchorage of Seats.

S.3.3 Folding and hinged seats. Except for folding auxiliary seats and seats with backs which are adjustable for occupant confort only.

1. Is it correct to interpret that the underlined part is referring to seats with backs reclining mechanism enabling to adjust the angle of the back?

ANSWER: Yes.

2. Or, should we interpret that the seats with reclinable backs come under the hinged seats?

ANSWER: No.

3. a. In the case of car with four doors, if the front seats are those with reclinable backs, these are presumed to be the ones corresponding to (1). Is this interpretation correct?

ANSWER: Yes.

b. In the case of a car with two doors, we would like to interpret that only the reclinable seat backs with folding mechanism enabling the passenger on the rear seat to get in and out are in conformity to (2). Is our interpretation correct?

ANSWER: Yes.

S.3.3.1 The release control shall be readily accessible to the occupant of that seat and to the occupant of any seat immediately behind that seat.

1. The above stipulation is presumed to be laid down for the egress of the passengers on the rear seat. Therefore, when the reclining seats are installed in a four-door car, we would like to consider it unncessary to pay regard to the underlined part. Is this interpretation correct?

ANSWER: Yes.

2. In the case of a two-door car, if the control which can be easily operated by passengers on the rear seat is installed only on one side (the right side), the passengers on the rear seat can operate the control by moving to the right side. Consequently, we consider it sufficient to install only on the right side the control which is easily accessible to the passengers on the rear seat. Is this interpretation correct?

ANSWER: In the case of a two-door car, for a split back or bucket seat arrangement, where both seat backs fold, a release control should be provided on the outboard side of each folding seat back. If the seat back is split and only one seat back folds, only one release control is required on the outboard side.

e. MVSS No. 210 - Seat Belt Assembly Anchorages

1. We judge that the fastening strength of the seat belt anchorage will change, depending on the shape of the eye bolt attaching the seat belt to the seat belt anchorage point.

If an anchorage is tested by using our designed seat belt assembly and the strength of the anchorage can be assured, we understand that the anchorage fully conforms to the standard, and also understand that it is not necessary to guarantee the owners of Mazda vehicles if they attach a seat belt assembly other than the one designated by us. Is our interpretation correct?

We, of course, will specify in our Operation Manual that the seat belt assembly designated by our company must be used.

ANSWER: Under Paragraph S.5.1 of Federal Motor Vehicle Safety Standard No. 210, anchorages are to be tested by using a Type 1 or Type 2 seat belt assembly as defined in FMVSS No. 209. If you follow this procedure, using a belt which complies to No. 209, and your anchorages meet the requirements of Standard No. 210, then you are in compliance with this standard.

I must point out that this Bureau does not issue approvals on items of equipment or on vehicle designs. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the Standards.