ID: nht92-3.30

DATE: October 2, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Dan Trexler -- Thomas Built Buses

TITLE: None

ATTACHMT: Attached to letter dated 9/14/92 from Paul Jackson Rice to Lyle Walheim (Std. 131) and letter dated 8/10/92 from Dan Trexler to Paul Jackson Rice (OCC-7641)

TEXT:

This responds to your letter requesting an interpretation of the requirements set forth in Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices. I am pleased to have this opportunity to respond to your questions about requirements addressing the activation of a stop signal arm and the permissibility of a manual override device. In addition, I am enclosing a September 14, 1992 interpretation letter from this agency to the Wisconsin Department of Transportation, which explains these requirements.

As your letter indicates, there are two different types of lamp systems on school buses: a four lamp system with four red lamps and an eight lamp system with four amber and four red lamps. You asked several questions about the stop arm's activation and the manual override device.

You first ask whether the stop arm is required to extend every time the signal lamps in a four lamp system are activated. (emphasis in original). As a general rule, S5.5 of Standard No. 131 requires that the stop arm be automatically extended at a minimum whenever the red signal lamps are activated. Nevertheless, Standard No. 131 includes an exception to this general rule which permits the installation of an override device. If the override device were activated, then the stop arm would not extend.

Your second question addresses the operation of the stop arm on buses with an eight lamp system. Specifically, you ask whether the stop arm is required to extend only after the red signal lamps have been activated by opening of the bus entrance door or is the stop arm required to extend at any time the red signal lamps are activated. (emphasis in original).

As stated above, Standard No. 131 includes provisions addressing the activation of the stop signal arm. Standard No. 131 requires the stop arm to be automatically extended whenever the red signal lamps are activated, whether those lamps are activated by opening the bus door or for some other reason. Of course, the stop arm may be extended for a longer period of time than when the red signal lamps are activated, given that Standard No. 131 includes the phrase "at a minimum" in explaining when the stop arm must be extended. In the final rule establishing Standard No. 131, the agency addressed methods of stop arm activation used by Washington State, Illinois, and Florida in which the stop arm was activated to control traffic before the door was opened. (56 FR 20363, 20368, May 3, 1991).

Your third question asked whether a device may be used that is capable of remaining in the "override" position with only a one time activation by the driver. The override would have an audible signal that would automatically

sound for at least 60 seconds and would automatically recycle each time the service door was opened, with the engine running. As mentioned above, Standard No. 131 permits a device that prevents the automatic extension of the stop signal arm. In our September 14, 1992 letter to Mr. Lyle Walheim from the State of Wisconsin, we explain a situation in which an override would be permissible. Based on S5.5 of Standard No. 131 and the September 14, 1992 interpretation to Mr. Walheim, it would appear that the override device you describe also would be permissible.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht92-3.31

DATE: 10/02/92

FROM: MARK W. STEVENS -- CHAIRMAN, SEATMORE

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO MARK W. STEVENS (A40; STD. 207; STD. 208; STD. 209; STD. 210; STD. 302; VSA 108

TEXT: We are in the process of designing and manufacturing a after market 3rd rear facing seat for the Ford Taurus and Mercury Sable station wagons 1986-1993.

The Product information contained in these document is proprietary and confidential trade secret information of Seatmore. We ask that this information be kept confidential.

We have asked Johnson Safety in California to manufacture the 3rd seat described in these documents, they have contacted James Gilkey in Code Enforcement Division. Mr. Gilkey suggested that we contact you with the following questions in order to know proper testing requirements.

1. Does the aftermarket 3rd rear facing station wagon system have to be tested in compliance with FMVSS 207, 209, & 210?

2. The seat belt anchorages are Ford factory anchorages built into the car at the factory and designed specifically for the Ford factory 3rd seat and seat belts. We will be using the same anchorages with aftermarket seat belts already in compliance. Is a test required for this system?

3. If testing is required, must they be specifically Static Tested or Dynamic Crash Tested?

I have enclosed pictures with descriptions of the seat and Ford factory mountings for your review.

Please feel free to call if you have questions or need further information. We are ready to take this product to the auto aftermarket and we would appreciate your review and response as soon as possible.

ID: nht92-3.32

DATE: 10/02/92

FROM: FREDD SCHEYS -- PRESIDENT, S.C.C. CARAT INC.

TO: PAUL J. RICE -- CHIEF COUNSIL, NHTSA; TAYLOR VINSON

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO FREDD SCHEYS (A40; PART 567)

TEXT: Since our phone convertation on monday 9, 28, 1992, I would like to ask four your advice regarding the following questions.

I am the official importer for CARAT DUCHATELET from Belgium. From the accompanying literature you can see the history of our company and the kind of work we do on Mercedes Benz and Rolls Royce motorcars.

Since my first year here, I have conducted market surveys pertaining to the need for the type of convertions which we offer.

I now have a customer here in the United States who would like his cars under go our conversion process. This particular klient lives in California and has allready purchased two new Mercedes Benz cars, U.S. specs, type 600 SEL. Both cars are titled in de owners name. He would like for our company to install a stretch convertion and in this case I would send these cars to our company in Belgium. There they would be stretched by an additional thirty-nine inches and the cars would than be shipped back to the United States. My questions is, what are the regulations which we will have to follow in this case?

Also I would like to ask four your advice for the next case; An American klient can buy his U.S. spec car from a local Mercedes dealership with delivery from the Mercedes factory in Germany. When the car is ready he flyes to the factory and takes delivery of his car. After a trip in Europe he leaves his car in our company for a stretch convertion. After this convertion is done we ship the car back to the customer in the United States. . What are the regulations we will have to follow in this case?

Also I like to ask your advice for the case where we have to convert a car into a armoured car.

I would like to thank you for your help and advice in these matters.

(ATTACHMENT OMITTED.)

ID: nht92-3.33

DATE: October 1, 1992 Est.

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: C. Morris Adams

TITLE: None

ATTACHMT: Attached to letter dated 9/24/92 from C. Morris Adams to Paul Jackson Rice (OCC-7768)

TEXT:

This responds to your FAX of September 24, 1992, requesting a ruling regarding the legality of lap belts at the passenger seats on school buses. As explained below, Federal law has long required lap or lap/shoulder belts to be installed at every passenger seating position on small school buses. Federal law has also long permitted, but not required, lap or lap/shoulder belts to be installed at passenger seating positions on large school buses, provided that those belts do not adversely affect the large school bus's compliance with the applicable safety standards. This is still the agency's position.

As you know, in 1977, NHTSA issued Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection, which established minimum levels of crash protection that must be provided for occupants of all school buses. For large school buses (those with a gross vehicle weight rating (GVWR) of more than 10,000 pounds), the standard requires occupant protection through a concept called "compartmentalization" -- strong, well-padded, well-anchored, high-backed, evenly spaced seats. Small school buses (those with a GVWR of 10,000 pounds or less) must provide "compartmentalization" and be equipped with lap or lap/shoulder belts at all passenger seating positions. The agency believes that safety belts are necessary in addition to "compartmentalization" in small school buses because of their smaller size and weight, which are closer to that of passenger cars and light trucks.

Ever since 1977, NHTSA has indicated that Federal law permits lap or lap/shoulder belts to be installed at the passenger seating positions on large school buses as long as the vehicle would still comply with all applicable safety standards, including Standard No. 222. NHTSA has no information to indicate that installation of seat belts at the passenger seating positions on a large school bus would affect the bus's compliance with any safety standard.

The allegations in your FAX that using seat belts in large school buses will result in crash forces producing concentrated loading on the head, instead of being spread evenly over the upper torso as is the case without a seat belt, are nearly identical with the explanations included in a 1985 Transport Canada report on school bus safety. NHTSA carefully evaluated and considered the Canadian report and these explanations in connection with its rulemaking action considering whether to specify requirements for voluntarily installed seat belts on large school buses. 54 FR 11765; March 22, 1989. After fully considering the Canadian report, the agency stated at 54 FR 11770: NHTSA shares commenters' concerns about any implications that safety belts negatively affect the protection provided to passengers on large school buses. However, the agency is not aware of accident data showing an injury caused or made more serious by the presence of safety belts on a school bus. Furthermore, NHTSA cannot conclude from the Canadian report's findings that belts actually degrade the benefits of compartmentalization to the extent that the supplemental restraint system renders inoperative the safety of large school buses, but the possibility exists that the occupant kinematics shown in the Canadian tests could occur.

The agency then identified some possible safety benefits that could result from seat belts in large school buses, benefits that were not considered in the Canadian tests. The agency concluded that, "Although these benefits are not significant enough to justify a Federal requirement for the installation of safety belts on all large school buses, they are enough to provide a basis upon which the agency will decline to prohibit the installation of belts on large school buses." 54 FR 11765, at 11770; March 22, 1989. I have enclosed a copy of this notice for your information.

As you can see, NHTSA has carefully considered the subject raised in your FAX and reviewed all available information in this area. After that review, the agency concluded that there was no justification for changing its longstanding position that persons that wish to do so should be permitted to install seat belts at passenger seating positions in large school buses. Your letter did not provide any data that NHTSA had not already considered. Hence, there is no basis for the agency to change its longstanding position in this area.

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: nht92-3.34

DATE: 10/01/92

FROM: MICHAEL J. VACANTI

TO: OFFICE OF THE CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO MICHAEL J. VACANTI (A40; STD. 208; VSA 108)

TEXT: I, Mike Vacanti, have designed an after market seat belt accessory to help fit the shoulder strap and the lap belt properly on small children.

Information on this device is enclosed. Please evaluate this information and offer a ruling as to the compliance with current Federal standards.

Also, enclosed please find a self addressed, stamped envelope for convenience in replying. Your prompt attention will be greatly appreciated. Thank you for this consideration.

Attachment

"Embrace" - Child Safety Seat Belt Accessory

PREMISE:

At the age of four, children can legally ride in a car without a "child safety seat" (car seat). To date, auto manufacturers have not made available any device to properly fit the shoulder strap of the seat belt to small children (roughly ages 4-10 years). Without a proper fit, the shoulder strap of the seat belt will the cross the small child near the head and neck area. Therefore, parents generally will loop the shoulder strap behind the small child, or behind the passenger seat. Neither method is safe.

THE DEVICE:

"Embrace", child safety seat belt accessory will effectively fit the shoulder strap of the seat belt to a small child. (See drawing B1).

"Embrace" is a polyurethane device that latches onto the lap belt of the seat belt and also to the shoulder strap of the seat belt, changing the angle at which the belt crosses the child's upper body in front of the child. (See Drawing A1).

USAGE:

I believe this device can be widely used with any and all automobiles that employ a shoulder strap with the seat belt. This device should not be limited to children. Size variances can be developed to fit different groups, such as senior citizens, physically challenged individuals or other special needs. The first application of the device will be children.

DESIGN: This device was initially conceived by Michael Vacanti in the year 1991. After testing with mock-up and redesigning, this device if believed to be ready for production.

(GRAPHICS OMITTED)

ID: nht92-3.35

DATE: 10/01/92

FROM: JESS R. THURMAN

TO: MARY VERSAILLES -- OFFICE OF CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO JESS R. THURMAN (A40; STD. 207; STD. 208; STD. 209; STD. 210)

TEXT: On September 23, 1992, I talked to Mr. Jim Gilkey in the engineering department of National Highway Safety Admn. about moving seats and seat belts in a new Van. He informed me that he did not know the complete law on this. He advised me to write to you about this and explain my problem. He said that maybe each handicap case could be reviewed and some change could be made.

I am a disabled veteran confined to a wheelchair, wanting to buy a new Ford Van converted to my use with a wheelchair lift. I now have a 83 Ford Van with a lift. The two passenger captains chairs are moved back to make room for my wheelchair to enter. The bench seat is moved to the rear as for as it will go when lying down or up right. This makes it possible to keep all the seats in the Van for my family & I to take trips. This was all done before the law was passed that the seats & belts could not be moved. The chairs in my Van have floor seat belts, so it was no problem to move them.

With the new Vans, the three point hitch safety belts can not be moved according to law. Van Conversion Companies will not move the seat belt hook up, nor will the ford dealer.

If I have the two seats out, all I would have left is a bench seat for three people in the rear. It would be a shame to spend all this money for a Van and loose two seats.

If the two passenger captain chairs could be moved back about 30 inches and the seat belt hook up moved to match the chairs, this could all be done at the Van conversion plant. This way the seat and belts would be okay and safe.

My question is this, can these three point seat belts and chairs be moved back? If this could be moved may I have a letter to confirm that this can be done so that when I purchase a new Van I can take the letter and they can follow your instructions.

If you have any questions, please feel free to call me at 812-867-2857.

Thank you for your assistance in this matter.

(ATTACHMENT OMITTED.)

ID: nht92-3.36

DATE: 09/30/92

FROM: EDNA SUTLIEF -- PROJECT CONCERN (ATCHISON, KANSAS)

TO: CHARLES GAUTHIER

TITLE: REQUEST FOR WRITTEN RESPONSE REGARDING USE OF SEATBELTS AND TIEDOWNS

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO EDNA SUTLIEF (A40; STD. 208; STD. 209)

TEXT: Mrs. Edna Sutlief at Project Concern in Atchison, Kansas has requested written response regarding the use of seatbelts and or the use of tiedowns in vans used for transporting disabled and senior citizens at Project Concern.

I spoke with Art Neill who confirmed for me that there are no Federal mandates which cover seatbelt use for handicapped Passengers in lift-equipped vans. Mrs. Sutlief would like something in writing stating this, because she has a driver who is refusing to drive a van unless all passengers are using seatbelts.

Since The state of Kansas mandates the use of seatbelts only in front seats, Mrs. Sutlief is concerned that she or the Project Concern staff will be in violation of Section 504 of the Rehabilitation Act if they insist on seatbelts or tiedowns for disabled passengers riding in the rear of vans. I suggested posting something in each van encouraging the use of belts for everyone, and agreed to speak with someone about her request for something in writing.

Because of ADA and increasing awareness of the need to treat all equally in facilities such as Project concern, calls of this nature will probably increase. The hotline staff should have more information on how to answer these

ID: nht92-3.37

DATE: September 29, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Mark V. Schwartz -- Account Executive, Entran Devices, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/9/92 from Mark V. Schwartz to Paul Jackson Rice (OCC-7514)

TEXT:

This responds to your request for an interpretation of 49 CFR Part 572, Anthropomorphic Test Dummies. Specifically, you were interested in the provisions for the Hybrid III test dummy set forth in Subpart E of Part 572. You noted that S572.36(g) provides that the thorax and knee impactor accelerometers "shall have the dimensions and characteristics of Endevco Model 7231c or equivalent." You provided a sheet setting forth dimensional and electrical response information for an accelerometer model produced by your company, the Entran EGE-72C-750. You then asked if the Entran EGE-72C-750 was "equivalent" to the Endevco Model 7231c, within the meaning of S572.36(g). I am pleased to have this opportunity to explain our regulation for you.

Part 572 sets forth specifications with which all test dummies must comply if those dummies are to be used in this agency's compliance testing. In NHTSA's compliance testing to date, we have used only the Endevco Model 7231c for the thorax and knee impactor accelerometers. This should not be misinterpreted as suggesting that this agency believes that only this particular make and model of accelerometer will perform acceptably in compliance testing. Instead, it means that the agency has found that the Endevco Model 7231c performs acceptably in the intended shock environment, in terms of frequency response characteristics, damping, linearity, transverse sensitivity, reliability, repeatability, durability, etc.

The dictionary defines "equivalent" as "equal in value, measure, force, effect, significance, etc." As noted above, NHTSA has used only the Endevco Model 7231c for the thorax and knee impactor accelerometers in the compliance testing to date. Thus, the agency has not made any determination of which accelerometers are equivalent to the Endevco Model 7231c. Until such time as the agency makes a determination about equivalent accelerometers, the issue of equivalency of your EGE-72C-750 model and the specified accelerometer model is a matter to be worked out between your company and prospective users of your company's accelerometers. As long as you can satisfy prospective users about the equivalence of your company's accelerometers, NHTSA will not review the use of any particular accelerometers in certification testing, unless the test results indicate a problem or problems caused by those accelerometers.

I hope this information is helpful. If you have any further questions; or need some additional information on this subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

ID: nht92-3.38

DATE: 09/29/92

FROM: DONALD G. MCGUIGAN -- FORD MOTOR COMPANY, OFFICE OF THE GENERAL COUNSEL

TO: KENNETH N. WEINSTEIN, ESQ. -- ASSISTANT CHIEF COUNSEL, LITIGATION DIVISION, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-20-92 FROM PAUL J. RICE TO DONALD G. MCGUIGAN (A40; STD. 114)

TEXT: This letter requests NHTSA's concurrence in our interpretation of how compliance with the newly-effective amendment to Section 4.2 of Federal Motor Vehicle Safety Standard No. 114 appropriately may be demonstrated. Our associated company, Mazda Motor Corporation, informs us that in designing the key-locking and shift control mechanisms for the Ford-built 1993 Escort and Tracer vehicles, as well as for certain Mazda vehicles, it understood that compliance with the "key-locking system" requirement of the recently-amended FMVSS 114 was to be demonstrated by attempting to remove the ignition key with the transmission shift lever in each of the available gear selector positioning detents. When so tested, the key-locking systems of 1993 Escort and Tracers "prevent removal of the key" except when the transmission shift lever is locked in the "Park" detent.

We have become aware of speculation that it would be appropriate to test compliance with S4.2's "key-locking system" requirements by deliberately placing the transmission shift lever at various points between the "Reverse" and "Park" position gear selector detents while attempting to remove the ignition key. When so tested, the shift control system on at least a large proportion of 1993 Escorts and Tracers can be manipulated to one or another spot -- varying from vehicle to vehicle -- at which the key can be removed while the selector lever is held short of engaging the "Park" positioning detent. (Because the parking pawl will be engaged in or abutted on the park gear, the vehicles will not be free to roll more than a matter of inches). We are informed and believe that it may be possible to induce key removal while the selector lever is mispositioned between gears in vehicles produced by other manufacturers, too.

Ford respectfully submits that a compliance test involving mispositioning of the shift control lever between gear positions would be inappropriate in light of the revised standard's purpose and history. Such a test would be premised on an assumption that a substantive purpose of the recent amendment to FMVSS 114 is to prevent shifting errors (i.e., to ensure that drivers attempting to shift into "Park" fully engage the park mechanism on the vehicle). Of course, the rulemaking record regarding the FMVSS 114 amendment to S4.2 repeatedly indicates that the primary purpose of the FMVSS 114 amendments is to ensure that children or other occupants of a vehicle parked on a slanted surface with the ignition off and the key removed will not be able to move the transmission shift lever out of the "Park" detent, thereby placing the transmission in a neutral mode and creating the potential for a rollaway accident.

There is no indication in the rulemaking history that the revisions of FMVSS 114 are intended to address shifting errors. Indeed, shortly after issuance of the amendment to FMVSS 114 in question, the agency appropriately concluded in another context that the potential for "inadvertent vehicle movement" incidents because of shift control mispositioning is "relatively small" and did not justify beginning a rulemaking proceeding. See, W. A. Barr, 55 Fed. Reg. 25340 (June 21, 1990).

A test based upon mispositioning the shift control lever also seems inappropriate for the additional reason that no peculiar hazard arises because the transmission shift lever may have been left in-between the "Reverse" and "Park" detents. In assessing any safety implications related to an unattended child in a parked vehicle, it must be remebered that NHTSA had permitted manufacturers to have until September 1, 1993 to install covers that would "childproof" the key-lock system override button. Thus, at least in vehicles produced before September 1, 1993, a child who pushed the override button could move the transmission shift lever in a parked vehicle with the key removed, regardless of whether or not the transmission shift lever had been properly positioned in the "Park" detent.

More importantly, since the key-locking system requirement of FMVSS 114 only covers the situation where the ignition has been turned off by removal of the key, the possibility of vehicle movement addressed by the standard involves only unpowered rollaway, and arises only if the vehicle has been parked on a slanted surface without the parking brake having been set. Thus, the scenario envisioned by the revised standard involves even smaller potential for injuries due to inadvertent vehicle movement than the scenarios assessed by NHTSA when it evaluated the Barr petition which included, among other things, powered movement of unattended vehicles.

We hope that you are in agreement with our view of the appropriate approach to FMVSS 114 compliance testing. Assuming this to be the case, we would appreciate your confirming this by return correspondence. We are available to discuss this matter with you at your convenience.

ID: nht92-3.39

DATE: September 28, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Robert N. Moore -- No. 203048, Iowa State Penitentiary

TITLE: None

ATTACHMT: Attached to letter dated 8/16/92 from Robert N. Moore to Mr. Curry (OCC-7681)

TEXT:

This responds to your letter of August 16, 1992 to former Administrator Curry. Specifically, your letter asks whether the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq., the Safety Act) and Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208) a right which is enforceable under the authority of 42 U.S.C. S1983. You have raised this issue in a law suit concerning injuries you received while being transported in a passenger van that had been converted into a "paddy wagon." The vehicle was not equipped with safety belts for the passengers. I am pleased to have this opportunity to explain for you the Safety Act and the Federal motor vehicle safety standards.

Let me begin by making clear that I have no special knowledge or expertise with respect to the civil rights provisions of 42 U.S.C. 1983. My answer will address only the requirements of the laws and regulations administered by this agency.

The Safety Act authorizes this agency to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA has exercised this authority to establish Standard No. 208, which requires seat belts to be installed at all designated seating positions in most vehicles. However, different belt installation requirements apply depending on the vehicle type, seating position within the vehicle, and the GVWR of the vehicle. Accordingly, I cannot identify the specific belt installation requirements for the vehicle in which you were transported without knowing the date of the vehicle's manufacture, the vehicle's seating capacity, and gross vehicle weight rating (GVWR) of the vehicle.

The Safety Act provides that no person shall manufacture, import, or sell any new vehicle unless it complies with all applicable Federal motor vehicle safety standards, including the seat belt installation requirements in Standard No. 208. See 15 U.S.C. 1397(a)(1)(A). The requirement that a vehicle comply with all applicable safety standards applies only until the vehicle's first purchase in good faith for purposes other than resale. See 15 U.S.C. 1397(b)(1). After such first purchase, the only provision in Federal law that affects modifications that can be made to the vehicle is set forth in 15 U.S.C. 1397(a)(2)(A). That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

Please note that this prohibition applies only to the commercial entities identified in the section, not to individual vehicle owners. Vehicle owners may alter their own vehicles and operate them on the highways without violating Federal law, even if the owner's modifications cause the vehicle to no longer comply with the seat belt installation requirements of Standard No. 208.

Thus, I cannot offer an opinion about whether there may have been a violation of the Safety Act without knowing if the passenger van was modified into a "paddy wagon" before or after its first purchase for purposes other than resale and who performed the modifications. If the State purchased the vehicle and made the modifications itself, there would have been no violation of Federal law, even if the modified vehicle did not comply with the seat belt installation requirements of Standard No. 208. Such modifications may, however, violate the laws of the State of Iowa. You may wish to contact the State of Iowa to learn if it has adopted any laws or regulations pertaining to owners' modifications to their vehicles.

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