ID: nht87-2.99

TYPE: INTERPRETATION-NHTSA

DATE: 09/21/87

FROM: DALLAS MCCLAIN -- PRO TOUR, INC.

TO: OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: CLARIFICATION/INTERPRETATION OF SEATING STANDARDS

ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 FROM ERICK Z. JONES TO DALLAS MCCLAIN; REDBOOK A-32, STANDARD 207

TEXT: Dear Sir,

Upon the recommendation of your technical reference division, I have formulated my inquiries to your office for interpretation and clarification. This company is a manufacturer of bus seating (NON-School bus) and we believe we surpass all applicable Fed eral Motor Vehicle Safety Standards. There are some points which we would like a legal opinion on for our customers as well as ourselves. Below are several questions which your office will hopefully be able to answer for us. Thank you.

A. What is the legal determination of a 'bus' as opposed to a 'multipurpose vehicle'? Is this definition based on number of passengers, or gross vehicle weight? Or both?

B. In the first paragraph of S4.2 of MVSS 207, there is reference to side-facing seats or passenger seat on a bus, which appear to be exceptions. Following this paragraph are the performance requirements. Are side-facing seats and passenger seats on a bus exempted from these performance requirements? Are these two items covered under another safety standard? If so, which one?

C. Keeping in mind we are assuming NON-School Bus applications, is perimeter seating a 'side-facing seat' such as mentioned above and does MVSS 207 testing apply to these seating configurations? Are there any existing requirements for cushions which are removeable such as perimeter seating arrangements? Or it is just the frame structure which must meet test specifications?

D. While seats not designated for use while the vehicle is moving (MVSS 207, S4.4) must be labeled, must other occupant seating subject to MVSS 207 and MVSS 302 be labeled with a 'law label' indicating the seat has met these standards?

Thank you very much for your help in resolving these questions. If further information is needed to render a finding, please feel free to contact me.

ID: nht87-3.1

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 22, 1987

FROM: JAN PETER KRYGER -- VICE PRESIDENT, QUICKWHEEL

TO: DEIRDE HOM -- NHTSA

TITLE: NONE

ATTACHMT: 9/22/87 (EST) LETTER TO JAN PETER KRYGER, FROM ERIKA 2. JONES

TEXT: The information you gave me over the phone, on September 18th, was very helpful.

Let me give you some information about Quickwheel. Imagine it as a "roller skate", that can be placed under a flat tire in just a few seconds. The driver can go on to the nearest service station or even go home. Since it takes just a few seconds, Quic kwheel promotes traffic safety.

Quickwheel has been thoroughly tested by T.U.V. (THE authority in Germany) on the road and in traffic. In a letter to the "Bundesminister fur Verkehr" (the Secretary of Transportation in Germany) T.U.V. makes the following statement: the car equiped wit h Quickwheel handled speeds up to 45 miles flawlessly, even if the car had to come to a sudden stop or swerve to avoid an object.

Quickwheel, INC, has taken out a patent and is going to market Quickwheel in the U.S.A.

I have the following questions:

-What safety standards do apply to Quickwheel and its three little wheels?

-Do we need approval from the Department of Transportation and if so, what is the procedure?

-Could you explain the Code of Federal Regulations?

I am looking forward to your answer. Should you have any questions or suggestions, please let me know.

ID: nht87-3.10

TYPE: INTERPRETATION-NHTSA

DATE: 10/07/87

FROM: ANDREW E. WOOLNER -- GENERAL MANAGER AUSTIN ROVER

TO: ERIKA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: INTERPRETATION OF FMVSS NO. 101, CONTROLS AND DISPLAYS, SECTION S 5.3.5.

ATTACHMT: ATTACHED TO LETTER DATED 11/23/88, FROM ERIKA Z. JONES -- NHTSA, TO ANDREW E. WOLLNER -- AUSTIN ROVER, REDBOOK A33, STANDARD 101; BROCHURE FROM AUSTIN ROVER, UNDATED (RE CONTROLS AND DISPLAYS)

TEXT: Austin Rover Ltd. (ARG), the mamufacturer of the Sterling passenger car seeks an interpretation of FMVSS NO 101, Controls and Displays as of September, 1989.

1. All Sterling 825 vehicles have a fuel gauge and a speedodometer/odometer located in the instrument panel immediately in front of the driver as illustrated in Fig. 1.

2. The Sterling SL has in addition to the above-mentioned displays, a trip computer fitted in the center console (Fig. 2). This trip computer is able, among other functions to display supplemental information in relation to fuel consumption, (instan taneous and average), fuel used, average speed, trip distance and distance to arrival. The attachment shows the method of operation and the functions.

ARG interprets the illumination requirements of standard 101 as applicable to the trip computer display as being:

a. The illumination requirement not mandatory.

b. The illumination provided at the choice of the manufacturer is subject to the requirements of section S 5.3.5. and not section S 5.3.3.

The reasons for our interpretation are as follows:

a. The fuel section of the trip computer does not show the fuel level in the fuel tank.

b. The distance and speed functions cannot be considered as "speedodometer" because it does not indicate actual vehicle speed at any instant. Also there is no need to illuminate an odometer even if the distance function could be so considered.

Would you please confirm that ARG's interpretation for 1 and 2 above are correct. That is, that such displays contained in our trip computer which offer "supplemental information" to other gauges and displays that are clearly regulated by FMVSS NO. 101 will categorically fall under S 5.3.5 requirements for illumination.

Sincerely,

Enc.

ID: nht87-3.11

TYPE: INTERPRETATION-NHTSA

DATE: 10/07/87

FROM: RICHARD J. STROHM

TO: CHEVROLET DIVISION

TITLE: 1987 CHEVROLET CAPRICE 1G1BL51HOHX163146 9000 MILES

ATTACHMT: ATTACHED TO LETTER DATED 07/31/89 FROM STEPHEN P. WOOD -- NHTSA TO RICHARD J. STROHM. REDBOOK A33; FMVSS 207; VSA 108 [A] [2] [4] LETTER DATED 11/09/87 FROM RICHARD J. STROHM TO EDWARD JETTNER -- NHTSA; FMVSS 207; OCC 1362

TEXT: Gentlemen:

It appears that the front bench seat in my 1987 Caprice has been mounted closer to the front of the passenger compartment than the Impales I have driven over the past 10 years. Less leg room was evident when I first drove the new car and I have been una ble to move the seat back for enough to provide the past comfort I enjoyed.

By my measurement the seat is 3/4 of an inch closer to the dash and floorboard, and the same distance farther from the back seat than in my 1983 Impale. I use this car for business travel and would like to have the seat position adjusted back, to where I feel it was for many years. The delivering dealer (Horizon Chevrolet) is unable to do anything for me and I ask that you give them direction and authorization to make the seat adjustment under warranty.

I can bring the car by for examination if it would help.

Very truly yours,

ID: nht87-3.12

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 8, 1987

FROM: WES SPRUNK -- SAF-TEE SIPING & GROOVING INC.

TO: ERIKA JONES -- NHTSA CHIEF COUNSEL

TITLE: NONE

ATTACHMT: DECEMBER 30, 1988 LETTER FROM JONES TO SPRUNK, BROCHURES ON TIRE SIPING, 1978 NSC WINTER TEST REPORT, AUGUST 19, 1986 LETTER FROM KEIL TO SPRUNK, ARTICLE FROM AUGUST 1986 ISSUE OF "SCHOOL BUSINESS AFFAIRS," ARTICLE ENTITLED "SLASHING TIRES FOR SAFETY AND SAVINGS" FROM DECEMBER 1984 "NATIONAL SCHOOL BUS REPORT," MARCH 20, 1985 LETTER FROM GIFFORD TO SPRUNK, OCTOBER 15, 1982 LETTER FROM PALMER TO MARCY MANUFACTURING, AND APRIL 1983 AND APRIL 1984 ARTICLES FROM "GW SAFETY TALK"

TEXT: I have had a phone conversation with Ed Clancy concerning some problems that have arisen in reference to my product - with clarification from the National Highway Traffic Association.

I spoke, first of all, with Neil Thomas of the Federal Highway Administration and, later, with Jim Birtell, Head Engineer; they informed me that there was no problem with their department concerning siping tires in reference to the Federal Highway Admini stration. But, there was some question with a possible customer of mine with D.O.T.

For that reason, I would like to explain siping because, at this point, it is referred to in the D.O.T. Regulations in the same reference as grooving. We manufacturer and distribute both siping and grooving machines and I would like to clarify our posit ion and the difference in the two operations.

Grooving is a process of removing rubber from the tire to give it an additional space for water release. We sell grooving machines mainly to the metro bus companies who lease their tires and have considerable undertread.

Siping is a process of cross cutting the tread, never deeper than the original tread depth of the tire; and in most cases, 1/32" less, with a fine knife-either four of five cuts to the inch-that does not remove rubber. We have people siping tires on tru cks, buses, and passenger with excellent results. But, we have had some government agencies that want more clarification from your department.

I have enclosed for you a brochure on our siping machine and several testimonials from customers concerning their experience with siping so that you can better understand the process and the benefits derived thereform. In the cross cutting of the tread, the benefits are that it allows the tread to interact with the road and have the edges grap the road for better traction. It also allows for the tread components to open up enough to allow air to get into the tread and this helps with the increase in w ear by cooling the tread of the tire.

What I need to know from you is if there is any possible problem with the siping of new, used, truck, passenger, or light duty tires, assuming the siping is done as I stated above, with D.O.T. Regulations

Enc.

ID: nht87-3.13

TYPE: INTERPRETATION-NHTSA

DATE: 10/15/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: American Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Head, Administration Government Relations Department American Suzuki Motor Corporation P.O. Box 1100 3251 East Imperial Highway Brea, CA 92622-1100

Dear Mr. Petler:

This letter responds to your letter of June 12, 1987, stating that your company wishes to and the following additional language to the Part 567 certification label:

"This vehicle equipped for 800 lb./360kg payload. See owner's manual for additional information.

You further state your understanding that NHTSA has permitted manufacturers to put information on the certification label beyond what Part 567 requires. You include two samples (-A- and -a-) representing certification labels, showing alternative location s on the label for your statement. The sample you designate as -A- shows your statement just above the required vehicle identification number, and just below the statement that your vehicle complies with all applicable Federal motor vehicle safety standa rd. The sample you designate as -B- shows your statement just below all of the information 5567.4 requires a manufacturer to put on the certification label. You ask which sample the agency would find acceptable.

You are correct that the agency his permitted manufacturers to include information on the certification label beyond that which Part 567 requires. There NHTSA has acquiesced in this practice, the additional information appeared after that required under 5567.4(g). Sample B shows the placement of your additional statement after the required Part 567 information. NHTSA finds that Sample B is acceptable so long as your label otherwise complies with Part 567. Sincerely,

Erika Z. Jones Chief Counsel

Erika Z. Jones, Esq. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Part 561 - Request for Interpretation

Dear Ms. Jones:

On behalf of Suzuki Motor Co., Ltd., of Japan, we are requesting an interpretation of Part 567-Certification, 567.1, as it applies to the placement of additional wording in the form of a statement addressing vehicle payload on the vehicle certification l abel. The additional statement reads:

"This vehicle equipped for 800 lb./360kg payload.

See owner's manual for additional information."

I have attached a drawing showing the statement placed in two different locations as illustrated in samples A and B. Suzuki's preference is sample A with the added statement being placed between the vehicle conformity statement and the VIN. If sample A p lacement is not acceptable to NHTSA. Suzuki would use sample B placement with the added statement appearing below the vehicle type description.

It is our understanding that NHTSA has permitted the use of additional wording or information on certification labels in response to requests like ours from other manufacturers. Suzuki also believes the addition of payload information for this particular vehicle would be of value to the vehicle owner.

Thank you for your assistance in this matter. We look forward to your prompt response to our request for interpretation. Sincerely,

AMERICAN SUZUKI MOTOR CORPORATION

Frederick M. Petler Head, Administration Government Relations Department

FMP:bf

ID: nht87-3.14

TYPE: INTERPRETATION-NHTSA

DATE: 10/15/87 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: CHRISTINE COTTLE -- OFFICE ADMINISTRATOR, CLASSIC AUTO ACCESSORIES

TITLE: NONE

ATTACHMT: MEMO DATED 6-30-87, FROM CHRISTINE COTTLE, TO ERIKA JONES-NHTSA

TEXT: This letter responds to your inquiry of June 30, 1987, where you ask for information "regarding any federal regulation that may apply to or restrict the use of items which might be suspended from the centered rear view mirror in an automobile or truck." In your letter, you refer specifically to "decorations" such as hanging dice and air fresheners, and express your company's wish "to avoid liability for any obstruction of vision which might occur as the result of the use of such items." Your letter does not say whether you manufacture the kinds of products you list, or install these kinds of products in motor vehicles.

First, please be aware that the National Highway Traffic Safety Administration (NHTSA) has authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA does not approve vehicles or equipment, n or does the agency endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a certification process under which each manufacturer must certify that its product meets agency safety standards, or other applic able standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.

A product would fall under our agency's jurisdiction if it is an item of "motor vehicle equipment" as that term is defined in @102(4) of the National Traffic and Motor Vehicle Safety Act. Section 102(4) defines "motor vehicle equipment" in relevant part as follows:

. . . any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component, or as any accessory, or addition to the motor v ehicle . . . (Emphasis added.)

In determining whether an item of equipment is an "accessory," the agency assesses two factors: first, whether the item has no ostensible purpose other than use with a motor vehicle; and second, whether the item is intended to be used principally by ordi nary users of motor vehicles. The kinds of products you list do not fall within this framework, and therefore NHTSA does not regard them as items of motor vehicle equipment subject to our regulations.

There is one section of the Safety Act that I would call to your attention. Among other things, @108 (a)(2)(A) of the Act states 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 or item of motor vehicle equipment in compliance with a n applicable Federal motor vehicle safety standard..."

If your company is among the persons or performs the kinds of operations in @ 108 (a) (2) (A), then it may not remove, disconnect, or degrade the performance of safety equipment or designs installed in compliance with an applicable Federal safety standar d. For example, you could not install any item in a motor vehicle that would render inoperative Standard 111 (Rearview Mirrors) "field-of-view" specifications. (I enclose a copy of that Standard.)

However, @108 (a) (2) (A) does not apply to vehicle owners. Therefore, owners may install items in their own cars, even if doing so involves removal, disconnection or degradation of safety equipment or designs, without violating @ 108 (a) (2) (A). Furt her, neither the manufacture of such items nor their sale to vehicle owners violates that prohibition.

Please note that a violation of @108 or of any regulation issued under it is punishable by a civil fine of up to $ 1000 per violation, subject to a maximum fine of $ 800,000 for a related series of violations.

Finally, you may wish to consult the laws of the various States to determine whether there are any limitations in their laws on the hanging of objects from inside rearview mirrors.

I hope you find this information helpful. ENCLOSURE

ID: nht87-3.15

TYPE: INTERPRETATION-NHTSA

DATE: 10/15/87

FROM: ERIKA Z. JONES -- NHTSA

TO: G.T. DOE -- LOTUS ENGINEERING, LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 02/05/87 FROM G.T. DOE TO ERIKA Z JONES; OCC 176; LETTER DATED 09/18/87 FROM ERIKA Z JONES TO J. DOUGLAS HAND

TEXT: Dear Mr. Doe:

This responds to your letter in which you asked how the conversion of a convertible to a hardtop would affect the applicability of two of our safety standards. I regret the delay in this response. You explained that Lotus proposes to introduce a new tw o seat convertible into the United States. These cars will be imported into the United States and delivered to dealers and distributors as convertibles. However, you stated that Lotus intends to offer a "factory manufactured and approved" hardtop conve rsion for these convertibles. Dealers would remove the convertible canopy and support frame and permanently attach a hard roof to the vehicle. The converted cars would be sold to the public as hardtops. You then asked whether the convertible cars would be treated as hardtops or convertibles for the purposes of Standards No. 208 and No. 216.

I would like to set the foundation for answering your specific questions by first addressing a few basic points. The agency has defined a convertible as "a vehicle whose A-pillar (or windshield peripheral support) is not joined at the top with the B-pil lar or other rear roof support rearward of the B-pillar by a fixed rigid structural member." In this case, your kit will join the A-pillar and B-pillar of the convertible by a fixed rigid structural member. After this conversion, the car would no longer be a convertible, as that term is used by NHTSA.

Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(1)(A)) provides that, "No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate com merce, or import into the United States, any motor vehicle ... manufactured on or after the date any Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard except as provided in subsection (b) of this section." This provision makes clear that a dealer would be prohibited from selling a hardtop passenger car that did

not comply with all safety standards applicable to hardtops, even though the passenger car conformed to all standards applicable to convertibles when it was imported and delivered to the dealer.

The exceptions set forth in section 108(b) of the Safety Act would not permit a dealer to sell a car that had been converted from a complying convertible into a hardtop without being modified to comply with all safety standard requirements applicable to hardtops. Section 108(b)(1) specifies that the prohibition on selling or offering to sell passenger cars that do not conform with all safety standards does not apply after the first purchase of the car in good faith for purposes other than resale. Howe ver, a dealer that converts a car into a different type before the first purchase could not rely on this exception.

Section 108(b)(2) specifies that the prohibition on selling nonconforming cars shall not apply to any person who establishes that he or she did not have reason to know in the exercise of due care that the car did not conform to the safety standards, or t o a person who holds a certification of conformity from the manufacturer or importer of the car, unless that person knows that the car does not conform. In the case of this proposed conversion, the dealers would hold a certificate of conformity from Lot us of the importer for the convertible version of this car. However, the dealers would also know that they had converted the car into a hardtop, and that they had no certificate of conformity for the car as a hardtop. Further, such dealers would have r eason to know that the requirements in the safety standards for hardtops are different from those for convertibles. Finally, the dealers would know that the hardtop version of the car had not been certified as conforming to all applicable standard requi rements. Indeed, as alterers of completed vehicles, the dealers would be required to recertify the cars under 49 CFR @ 567.7.

The exceptions to section 108(a)(1)(A)'s prohibition set forth in sections 108(b)(3)-(5) are not applicable in this situation. Hence, dealers could not legally sell these converted cars to the public for the first time, unless the cars conform with all safety standards applicable to hardtop passenger cars. With this background, I will now address your specific questions. They were:

1. Convertibles are not required to conform to the roof crush requirements of Standard No. 216, Roof Crush Resistance - Passenger Cars (49 CFR @571.216). Would the designation of the vehicle as a convertible remain unaffected by the hardtop conversio n?

ANSWER: As explained above, the answer to this question is no. Any car that is converted to a hardtop before its first sale for purposes other than resale must comply with all standards applicable to hardtops. Assuming such cars do not conform to the r ollover test requirements in section S5.3 of Standard No. 208 by means that require no action by vehicle occupants, these cars would be subject to the requirements of Standard No. 216.

2. Would the requirement for seating and restraint system provision remain unaffected by the hardtop conversion?

ANSWER: No. It is not clear to which seating requirements you are referring. However, you stated in your letter, "It is conceivable that, although the shelf would not be recognised as a seating area, small occupants could travel in this area." The requi rements for seating systems are dependent upon the existence of a "designated seating position." This term is defined in 49 CFR @571.3 as follows:

"Designated seating position" means any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design and vehicle design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats.

We cannot determine from your letter if the shelf area is capable of accommodating a 5th percentile adult female, nor can we determine whether the area's configuration and design is such that the position is likely to be used as a seating position while the vehicle is in motion. It appears from the enclosed drawings that any person riding in the shelf area would have to sit on the floor or prop themselves on the wheel wells. If this is true, the shelf area would not be considered to have any designate d seating positions.

The required occupant restraint system would also be affected by converting the convertibles into hardtops. As explained above, cars that are converted to hardtops by dealers before sale to the public would not be treated as convertibles for the purpose s of Standard No. 208, Occupant Crash Protection (49 CFR @ 571.208). Since the cars would no longer be considered convertibles, they would have to be equipped with lap/shoulder belts at both designated seating positions, pursuant to section S4.1.2.3.1 o f Standard No. 208. Additionally, these cars would not be eligible for the exemption for convertibles during the phase-in of the automatic restraint requirements in Standard No. 208. I sent a letter to General Motors (GM) on September 18, 1987, stating that GM may be considered the manufacturer of Lotus cars that are imported into the United States (copy enclosed). Therefore, any Lotus cars that are converted into hardtops would have to be included in GM's annual production to determine compliance wi th the phase-in requirement, pursuant to sections S4.1.3.1.2, S4.1.3.2.2, and S4.1.3.3.2 of Standard No. 208. I have also sent a copy of this letter to General Motors.

ENCLOSURE

ID: nht87-3.16

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 20, 1987

FROM: T. J. BROWN -- GENERAL MGR., PRODUCT SERVICES, MOHAWK TIRE COMPANY

TO: ERIKA Z. ZONES -- CHIEF COUNSEL, NHTSA

ATTACHMT: 11/23/88 letter from Erika Z. Jones to T.J. Brown (A33; Std. 109)

TEXT: The Mohawk Rubber Company is in the process of purchasing for resale, a group of metric size tires from a manufacturer in the Far East. It has come to our attention that the maximum load and maximum pressures molded on the sidewalls of the tires are ind icated in kilograms and kilopascals only without any indication of the maximum pounds and PSI pressure.

After reviewing MVSS #109, it is not clear as to whether or not these tires are in compliance with the standard and the purpose of this letter is to request your interpretation or ruling in this matter.

The actual stamping on the tires is indicated as follows: Size 165SR15 Load Range B Maximum Load 530kgs - Maximum Pressure 230KPA 185SR14 Load Range B Maximum Load 600kgs - Maximum Pressure 230KPA 175SR14 Load Range B Maximum Load 560kgs - Maximum Pressure 230KPA 165SR13 Load Range B Maxim um Load 475kgs - Maximum Pressure 230KPA 155SR13 Load Range B Maximum Load 420kgs - Maximum Pressure 220KPA

According to the European Tire and Rim Technical Organization, the loads and pressures are correctly designated on these tires, however, we do question if the omission of the load designation and pressure in pounds prohibits them being sold in the U.S .A.

We will appreciate your response to our request for a ruling in this matter.

ID: nht87-3.17

TYPE: INTERPRETATION-NHTSA

DATE: 10/20/87

FROM: JIM SCHULD -- MILL SUPPLY INCORPORATION

TO: CHIEF COUNSEL SECRETARY -- OFFICE OF CHIEF COUNSEL NATIONAL HWY. TRAFFIC SAFETY ADMIN.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO JIM SCHULD FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 207

TEXT: DEAR SIR:

WE ARE INTERESTED IN CONSTRUCTING A PASSENGER SEAT (JUMP SEAT) FOR TEMPORATY SITUATIONS IN WALK IN VANS. THIS SEAT WOULD BE REMOVABLE AND ABLE TO TRANSFER FROM ONE TRUCK TO ANOTHER.

WHAT ARE THE GUIDELINES WE NEED TO FOLLOW TO BE SURE WE WILL COMPLY WITH NATIONAL HWY AND TRANSPORTATION SAFETY ADMIN. PLEASE MAIL THIS INFORMATION TO THE ADDRESS ABOVE. ATT:JIM SCHULD.

SINCERELY,