ID: nht81-2.37

DATE: 06/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Tokai Rubber Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter regarding several new kinds of plastic vacuum brake hoses that you plan to manufacture. The plastic brake hoses are flexible nylon tubes for use in a vacuum braking system. You indicate that these hoses cannot comply with several provisions of Safety Standard No. 106, and ask whether the plastic hoses could qualify as "vacuum tubing connectors."

Safety Standard No. 106 (49 CFR 571.106) specifies performance and labeling requirements for brake hose, which is defined in the standard as:

"a flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes."

Since the nylon tubes which you plan to manufacture will transmit the vacuum used to apply force to a vehicle's brakes, the tubes would qualify as "brake hose" under this definition and would be subject to all requirements of Safety Standard No. 106. Moreover, it appears that the nylon tubes would not qualify as "vacuum tubing connectors," which are excepted from compliance with the standard in the definition of brake hose. Section 4 of Safety Standard No. 106 defines "vacuum tubing connector" as:

"a flexible conduit of vacuum that (i) connects metal tubing to metal tubing in a brake system, (ii) is attached without end fittings, and (iii) when installed, has an unsupported length less than the total length of those portions that cover the metal tubing."

According to the illustrated drawings included in your letter, the nylon flexible tubes with which you are concerned would have an unsupported length which is greater than the total length of those portions that cover metal tubing. Therefore, the nylon tubes would not qualify as "vacuum tubing connectors" under subsection (iii) of the above definition. The purpose of the definition is to except from compliance with the standard only those vacuum connectors that have unsupported lengths short enough that they will not sag or deflect because of their own weight. While your nylon tubes may be sturdy enough to meet this intended purpose, as the definition is currently written, the tubes cannot be considered vacuum tubing connectors.

If, as your letter indicates, the nylon brake hose does not comply with all requirements of Safety Standard No. 106, you would not be permitted to sell it in the United States. You may wish to petition the agency to amend Standard No. 106 to establish separate performance requirements specifically designed for nylon vacuum tubing such as that produced by Tokai. I am enclosing a copy of the procedures which explain how you can file a petition, in case you are interested.

Sincerely,

ID: nht81-2.38

DATE: 06/23/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Midwest Polychem, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: We have examined the proposed label for "GRC" brake fluid you have submitted to us for comment.

Generally, the label appears to meet the requirements of paragraph S5.2.2 of Motor Vehicle Safety Standard No. 116 (36 F.R. 11937, June 24, 1971, as amended, 36 F.R. 21594, November 11, 1971). The words "or(Illegible Word)" in your conformity statement are redundant; since the standard is a minimum requirement, "conforming to" and "exceeding" it mean exactly the same thing. If the fluid packager is an entity other than Curley, the packager's name or code identification must appear either below Gurley's name or on the bottom of the can. We assume that the required serial number identifying the packaged lot and date of packaging will be stamped either below Gurley's name or on the bottom of the can.

GRC

SUPER HEAVY DUTY

BRAKE FLUID DOT 3 MOTOR VEHICLE BRAKE FLUID 284 degrees F Min. Wet Boiling Point

GRC

HYDRAULIC BRAKE FLUID

DIRECTIONS

FILLING: Check fluid each month or every 2000 miles. Fill Mailer cylinder to within one-half inch of top.

BLEEDING: Remove plug from bleeder screw and insert bleeder hose. Place other and of bleeder in clean container partially filled with G.R.C. Brake Fluid. Lossen bleeder screw and pump brake pedal slowly until air bubbles stop and fluid is clear. Tighten blender screw and follow same instructions on all four wheels, Moster cylinder fluid level must be checked after bleeding each wheel and keep fluid level to within 1/2 inch of top.

CAUTION: FOLLOW VEHICLE MANUFACTURER'S RECOMMENDATIONS WHEN ADDING BRAKE FLUID.

KEEP BRAKE FLUID CLEAN AND DRY. Contamination with dirt, water petroleum products or other materials may result in brake failure or costly repairs.

STORE BRAKE FLUID ONLY IN ITS ORIGINAL CONTAINER. KEEP CONTAINER CLEAN AND TIGHTLY CLOSED TO PREVENT ABSORPTION OF MOISTURE.

CAUTION: DO NOT REFILL CONTAINER AND DO NOT USE FOR OTHER LIQUIDS.

(Illegible Lines) GURLEY REFINING DESIGN GCR SUPER HEAVY DUTY BRAKE FLUID (Illegible Word) 2700-1 S.O. 244-3191 SIZE 211 X 407.5 C.E. 4.595 X 8.364 B.P. DATE 10-19-71

(Illegible Lines) (Illegible Word) AS DETAINED APPROVED AS SUBMITTED CUSTOMER SIGNATURE: DATE NO. PROOFS 20 PROOF DATE 11-3-71 CHANGE A CHANGE B CHANGE C ARTIST D/TCA

ID: nht81-2.39

DATE: 06/25/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Japan Automobile Tire Manufacturers Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for an interpretation of the labeling requirements of Safety Standard No. 109 (49 CFR @ 571.109). Specifically, your association wants to know if Standard 109 permits tire manufacturers to include the letters "H," "S," or "V," as appropriate, in the tire size designation required to appear on the sidewall of passenger car tires by S4.3(a) of the Standard.

Such labeling is permitted by Standard 109. The speed rating symbols ("H," "S," or "V") established by the European Tyre and Rim Technical Organization, indicate that a tire is an acceptable high-speed tire. This permits, for example, a knowledgeable purchaser of tires for emergency vehicles to know that these tires are suitable for the higher operational speeds necessary for those vehicles. Use of these symbols in the size designation would not likely confuse the less sophisticated consumer, or otherwise defeat the purpose of the labeling information. Accordingly, use of these symbols is permitted under Standard 109.

If you have any further questions, or need further information on this matter, please feel free to contact Steve Kratzke of my staff (202-426-2992).

ID: nht81-2.4

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Williamsen Truck Equipment Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. F. E. Stephens Vice President, Marketing 1925 Indiana Avenue Salt Lake City, UT 84125

Dear Mr. Stephens

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

May 8, 1980

Administrator National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, DC 20590

ATTENTION: VIN coordinator Gentlemen:

We submit herewith our VIN number for the trailers we build as follows for your approval.

Williamsen manufactures end dump trailers, bottom dump trailers and trailer chassis as semi trailers, full trailers, and pony trailers in tandem axle, two axle, triple axle and four axle configerations as per drawings and pictures enclosed.

The Society of Automotive Engineers, Inc. has assigned to Willamsen a (WMI) code of 1W9 with the 3rd, 4th and 5th characters of the vehicle identifier section as: 004

Our model years starts October 1, 1980 through September 30, 1981 so our VIN number is constructed as follows:

1st, 2nd 3rd characters 1W9=Assignment from Society of Automotive Engineers, Inc.

1 = Full trailer 4th Character 2 = Semi-trailer 3 = Dolly (no body) 4 = Pony trailer

B = FRP Bottom dump C = Chassis only (no body) D = Steel Bottom dump 5th Character E = Steel end dump F = Aluminum bottom dump G = Aluminum end dump H = Steel sand master

6th & 7th Characters = Length, feet

8th Character = Number of Axles

9th Character = Check digit

10th Character = Year model

11th Character = S = Salt Lake City, Utah plant 0 = Ogden, Utah plant D = Dallas, Texas plant 12th, 13th, 14th Characters = 04 - Assignment from Society of Automotive Engineering, Inc 15th, 16th 17th Characters 001 thru 090 = Starting of production at beginning of our 1981 production year October 1, 1980 for each type and length of trailer. Then continuing each year thereafter with consecutive numbering until we reach 999 at which time we will start over again 001 thru 050. This should take several years.

Our Vehicle Identification Number (VIN) for trailers manufactured by Williamsen starting with first trailers of each type and size on October 1, 1980 will be as follows:

Two axle full trailer with:

Steel end dump body - 16' 1W9 1E162 0 BS004001 Aluminum end dump body - 16' 1W9 1G162 8 BS004001

Four Axle full trailer with:

FRP bottom dump body - 29' 1W9 1B294 6 BS004001 Steel bottom dump body - 29' 1W9 1D294 3 BS004001 Aluminum bottom dump body - 29' 1W9 1F294 0 BS004001 Chassis only (no body) - 20' 1W9 1C204 3 Bs004001

Tandem axle semi-trailer with:

FRP bottom dump body - 29' 1W9 2B292 2 BS004001 FRP bottom dump body - 37' 1W9 2B372 1 BS004001 FRP bottom dump body - 40' 1W9 2B402 1 BS004001

Steel Bottom dump body - 29' 1W9 2D292 X BS004001 Steel Bottom dump body - 37' 1W9 2D372 9 BS004001 Steel Bottom dump body - 40' 1W9 2D402 9 BS004001

Aluminum Bottom dump body - 29' 1W9 2F292 7 BS004001 Aluminum Bottom dump body - 37' 1W9 2F372 6 BS004001 Aluminum Bottom dump body - 40' 1W9 2F402 6 BS004001

Sandmaster Steel bottom dump body-41' 1W9 2H412 5 BS004001 Sandmaster Steel bottom dump body-47' 1W9 2H472 6 BS004001 Sandmaster Steel bottom dump body-51' 1W9 2H512 8 BS004001 Dolly:

Single axle - 06' 1W9 30061 5 BS004001 Tandem axle - 08' 1W9 30082 X BS004001

Two axle pup or pony trailer:

With steel end dump body - 25' 1W9 4E252 5 BS 00401 With aluminum end dump body - 25' 1W9 4G252 2 BS004001

Triple axle pup or pony trailer:

With steel end dumkp body - 24' 1W9 4E243 2 BS004001 With aluminum end dump body - 24' 1W9 4G243 X BS004001

We trust this meets with your approval and we may receive same shortly.

Sincerely,

WILLIAMSEN TRUCK EQUIPMENT CORPORATION

F. E. Stephens V. P. Marketing

FES/sr

enc. 03/17/81

ID: nht81-2.40

DATE: 06/29/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Devlin Associates

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your April 28, 1981, letter asking for information relating to the agency's recordkeeping requirements.

I have enclosed copies of the agency's major recordkeeping regulations and portions of one statute that requires the retention of information. This information describes the types of records to be retained and the periods that retention is required. The agency has not specified the form or location for record retention, but it has stated that records must be readily retrievable when necessary. The agency has not imposed a penalty for accidental loss of records. I can see no instance in which a penalty would be imposed for such an accidental loss.

Finally, you ask for any recommendations that we might have with respect to record retention. We only suggest that records be maintained in an easily accessible manner so that they can be used effectively in removing dangerous vehicles or equipment from the highway. Other than this general recommendation, the actual recordkeeping techniques that a company should use would depend upon the size and sophistication of the company.

If you have any questions concerning any of the materials that I have provided you, you may contact Roger Tilton of my staff (202-426-9511).

ENCLS.

DEVLIN ASSOCIATES, INC.

April 28, 1981

Roger Tilton Office of the Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Mr. Tilton:

RE: RECORDS RETENTION

We have been asked to identify "Records Retention" requirements for several clients. We have used the "GUIDE TO RECORD RETENTION REQUIREMENTS" as a starting point. However, we do require additional information. Please forward any additional information which will assist us to determine:

1. Specific records to be retained and retention periods.

2. Acceptable retention media (paper, film, microfiche, magnetic tape, etc.)--requirements for above (i.e., computer equipment and programs to read magnetic tape, etc.) 3. Location for retention of all data.

4. Penalty for loss (in particular, in case of fire, or accidental loss.)

5.. Recommendations

We will appreciate any assistance and information you can provide in this regard. Please address your response to my attention.

Judith I. Robey Executive Vice President

ID: nht81-2.41

DATE: 07/01/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Trelleborg AB, Tire Division

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking for information concerning the requirements of Safety Standard No. 119 (49 CFR @ 571.119), as it applies to motorcycle tires. Specifically, you asked what markings must be on the sidewalls of knobby motorcross tires (motorcycle tires designed for off-road use) to satisfy the requirements of Standard 119.

If your company designs the tires exclusively for off-road use, with no expectation that they will be used when the motorcycle is on the public roads, Standard 119 is not applicable to the tires. Therefore, no markings would be required on the sidewall of the tires. On the other hand, if you believe the motorcross tires will, in fact, be used on the public roads, as well as off-road, they must meet the marking requirements specified in section S6.5 of Standard No. 119 (copy enclosed).

Standard No. 119 and its marking requirements apply to all new tires designed for highway use on non-passenger-car motor vehicles. In response to the petitions for reconsideration of Standard 119, the agency stated that manufacturers of motorcross tires would have to determine if the tires were designed for highway use (see 39 FR 5191, February 11, 1974, copy enclosed). In the absence of a showing to the contrary, however, this agency would assume that motorcycles equipped with motocross tires are ridden on the public highways to and from race competition or trail use, which would mean the tires are subject to the requirements of Standard 119.

Following the publication of the above-mentioned notice, a manufacturer of motocross tires requested an interpretation of Standard 119, and stated that its motocross tires are not suitable for use on public roads, and are not designed for such use. The agency responded that such tires are not subject to the requirements of Standard 119, based on this set of circumstances.

However, as noted above, each manufacturer must make this determination. Please note that if you decide that the tires are not subject to Standard 119, 49 CFR Part 574 prohibits the DOT certification label from appearing on the sidewall of the tire. Please further note that a manufacturer's determination of this point is not dispositive. That is, this agency has authority to independently re-examine the manufacturer's determination. If the manufacturer's determination was incorrect, the manufacturer would be liable for civil penalties of up to $ 1,000 for each tire imported into this country which did not meet all the requirements of Standard 119. If you need any further information on this subject, please do not hesitate to contact me.

Sincerely,

ATTACH.

U.S. Department of Transportation -- National Highway Traffic Administration

FMVSS-119 Motorcycle Tires

Gentlemen,

Trelleborg AB, a Swedish Tire Manufacturer, Code no LW, plan to export motorcycle tires for motocross ( = Not for highway use) to USA.

Actual sizes are: 4.50-17 and 4.50-18.

Please tell us what we have to observe regarding the text on the tire walls.

Sincerely,

TRELLEBORG AB -- Tire Division;

Erik Sundelin -- Diplomengineer

ID: nht81-2.42

DATE: 07/01/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Airstream

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 26, 1981, letter asking for a clarification of the certification requirements applicable to vehicles that you manufacture. The units frequently are completed by you, but in some instances, they are shipped to a final manufacturer for completion of the interior work.

Your first question asks whether you should label the vehicle as a final-stage manufacturer since your vehicle is road worthy and needs only the addition of an interior finish prior to sale. In order to certify the vehicle as a final-stage manufacturer, the vehicle that you produce must be a completed vehicle (49 CFR Part 568). A completed vehicle is one that is finished and requires no further manufacturing operations to perform its intended functions with the exceptions of minor finishing operations or readily attachable components. If your vehicle is completed in a manner that it can perform its intended functions, you may label the vehicle as a final-stage manufacturer. The person performing alterations on your vehicle may then be required to add an alterer's label.

If the finishing operation that will be made to your vehicle is more than the attachment of readily attachable components or minor finish work, the person doing the finishing work may label the vehicle as a final-stage manufacturer. In determining whether the installation of a bathroom, kitchen, furniture, beds, appliances, or seats is an installation of readily attachable components, you should consider whether it requires special expertise or tools. If it requires either, it is not the installation of readily attachable components.

Your second question asks whether your vehicle would be considered a chassis-cab in those instances where another manufacturer might be attaching a final-stage label. The answer to this question is no. The definition of chassis-cab in part 567, Certification, states that it is a vehicle with a completed occupant compartment that needs only the addition of work performing or load carrying components to complete its function. It appears that your vehicle does not have a completed occupant compartment and, therefore, would not be considered a chassis-cab.

Finally, you ask what will happen if you label the vehicle as a final-stage manufacturer and a subsequent manufacturer significantly alters the vehicle. You ask whether you could treat the vehicle as an incomplete vehicle and furnish the documentation required by Part 568. If you label the vehicle as a final-stage vehicle, you cannot treat it as an incomplete vehicle. However, you may convey information similar to that conveyed in an incomplete vehicle document to the subsequent manufacturer to ensure that it can comply with all of the standards. In fact, that manufacturer may require such information in order to be able to make the necessary modifications.

ID: nht81-2.43

DATE: 07/07/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Carabela USA, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 8, 1981 requesting "the candlepower rating on a moped headlamp."

I enclose a copy of SAE Standard J584 Motorcycle and Motor Driven Cycle Headlamps April 1964, which contains the information that you request. Most mopeds develop 5 horsepower or less and thus qualify as a "motor driven cycle."

If you have any further questions, we shall be pleased to answer them.

ENC.

Carabela USA, Inc.

6-8-81

Office of Chief Council NHTSA

Dear Mr. Schwartz:

Please quote me the candlepower rating on a moped headlamp, if any. Thank you.

Barry N. Aebischer Mktg. Coordinator

ID: nht81-2.44

DATE: 07/07/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Burlington Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for an interpretation of Federal Motor Vehcile Safety Standard No. 117 (49 CFR @ 571.117). Specifically, you asked if the addition of "edger fabric strips", pursuant to a process covered by U.S. Patent 4,196,764, would violate the prohibition in section S5.2.2(b) of Standard No. 117 against adding belts to retreaded passenger car tires.

The described process is prohibited by section S5,2.2(b), because it is clearly adding a belt to the tire.

In the abstract of the subject patent, which you included in your request for an interpretation, is the following statement: "The invention relates to the use of reinforcing cords associated with the pneumatic tire . . ., and the method of applying such reinforcing cords woven in a warp and weft relationship cut in a bias shape to form a belt . . . ." Similarly, in the Detailed Description of the Preferred Embodiments section of the patent, Section 3 begins, "The essence of my invention is achieved by providing an extra belt . . . ." Hence, the patent itself states that this process involves the addition of a belt to retread tires. Such an addition is expressly forbidden by section S5.2.2(b) of Stanard 117; "No retreaded tire shall be manufactured with a casing on which a belt or ply, or part thereof, is added or replaced during processing."

Your letter stated that this edger fabric should not be considered a belt for purposes of the Standard, because the addition of the edger makes a retreaded tire safer and longer lasting. While you may be correct concerning the performance of "edger fabric," the Standard as currently written does not permit its use. If you wish, however, you may file a petition for rulemaking requesting this agency to amend Standard 117 to permit the addition of a belt such as edger fabric by following the requirements set forth in 49 CFR Part 552 (copy enclosed). If you choose to do so, please include all data showing that the addition of this extra belt makes the retreaded tire safer, and that the edger fabric belt would be compatable with the existing cords of the casing that is used.

Finally, let me point out that Standard 117 applies only to retreaded passenger car tires. There is no safety standard applicable to retreaded tires for vehicles other than passenger cars, and the use of this patented process on those tires would not violate any requirements of this agency.

Mr. Hugh Oates of my staff sends his regards.

ENC.

May 1, 1981

Office of Chief Counsel National Highway Traffic and Safety Administration Attention: Stephen Kratzke

Re: NHTSA Standard No. 117 - Retreaded Pneumatic Tires

Dear Sirs:

Upon suggestion by Mr. Stephen Kratzke, I am writing to request an interpretation of NHTSA Standard No. 117 relating to retreaded pneumatic passenger car tires. In particular I would appreciate a written opinion as to whether S 5.2.2(b) of the Standard would apply to a retreading process by which the tire was stripped and a recap containing "edger" fabric molded therein then bonded to the carcass. For your better understanding, please note that "edger" fabric is a narrow strip of fabric positioned on each side or shoulder of the recap around the entire perimeter of the tire. The strips are intended and believed to aid in the prevention of steel belts "turning up" and rendering the recapped tire unsafe.

A careful reading of Standard No. 117 convinces me that "edger" fabric strips which are molded into the retread prior to the retread being secured to the casing is not addition or replacement of a belt or ply to the casing as contemplated by Standard 117. In fact, the purpose of the "edger" fabric is entirely consistent with the purpose of Standard 117 in that it is intended to make a retreaded steel belted tire safer and longer lasting than if the fabric were not incorporated into the recap. To hold that the "edger" fabric falls within the language and intended scope of Standard 117 would therefore run counter to the purpose and policy considerations behind the Standard.

In order that you may more fully understand the nature of the recapping process utilizing an "edger" fabric incorporated into the recap, I have attached hereto a copy of a U.S. patent generally directed to the process and highlighted some of the more pertinent portions. I hope that the above is sufficient for full understanding of our request, but please do not hesitate to call me at (919) 379-4517 if I may offer further explanation.

We respectfully solicit an expeditious opinion on this matter and thank you for your assistance to us.

Richard E. Jenkins Assistant Patent Counsel

ATTCH.

ID: nht81-2.45

DATE: 07/07/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 12, 1981, concerning the strength requirements specified in Safety Standard No. 209, Seat Belt Assemblies, for a dual buckle (i.e., a two buckle unit) anchored in a vehicle by one common anchorage attachment.

As explained below, I disagree with your judgment that the standard does not deal adequately with the dual buckle design. Your proposal to test the dual buckle with 5,000 pounds of force is also incorrect; the correct force is 6,000 pounds.

Section 3 of the standard defines "hardware" as "a metal or rigid plastic part of a seat belt assembly." That section further defines "attachment hardware" as "any or all hardware designed for securing the webbing of a seat belt assembly to a motor vehicle." As described in your letter and shown in its attached photograph, the dual buckle has a common metal anchorage attachment. Since the purpose of that metal part is to secure the webbing to the vehicle, it is considered attachment hardware.

Section 4.3 (c)(2) specifies that "attachment hardware designed to receive the ends of two seat belt assemblies shall withstand a tensile force of at least 6,000 pounds or 2.720 kilograms without fracture . . . ." Since the common anchorage attachment is designed to receive the force created by the ends of two seat belt assemblies, it must meet the requirements of S4.3(c)(2).

You are correct that the attachment bolt is required to withstand a force of at least 9,000 pounds or 4,080 kilograms under paragraph S4.3(c)(1) of the standard.

Sincerely,

MARCH 12, 1981

F. BERNDT, CHIEF COUNSEL -- U.S. Department of Transportation, NHTSA

Dear Sirs,

FMVSS 209

We have been asked to test for FMVSS approval a Dual Buckle anchored in the vehicle by one bolt, the Dual Buckle having common anchorage attachment.

The standard does not cope fully with this design and I suggest that it is tested in the following manner. The Dual Buckle should be tested statically at 5000 lbs and survive this test. This test would be in addition to the loop load test. The anchorage bolt would be tested to 9000 lbs. I have chosen 5000 lbs as a test limit for the following reason. The loop load test is done at 5000 lbs, the attachments being subjected to a load of 2500 lbs during this test. To prove the dual buckle we need to test it statically at twice this load of 2,500 lbs i.e. 5,000 lbs.

I would appreciate your comments on my proposal.

I have also written this letter to Mr A Cardarelli of AAMVA.

Yours faithfully

J E BINGHAM -- MOTOR VEHICLE SAFETY COMPONENTS SECTION, BRITISH STANDARDS INSTITUTION

(Photo Omitted)