ID: nht81-2.11

DATE: 03/30/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 30 1981

NOA-30

Mr. Karl-Heinz Ziwica Manager Safety & Emission Control Engineering BMW of North America, Inc. Montvale, NJ 07645

Dear Mr. Ziwica:

This responds to your letter of February 13, 1981, requesting an interpretation of Safety Standard No. 127, Speedometers and Odometers. The odometer/speedometer assembly that BMW wishes to use in its vehicles is built to comply with S4.2.5.2, the encapsulation requirements. The encapsulation consists of plastic "box" having the speedometer/odometer face and lens as its front. The front, top, bottom, and sides of the box are all one piece. The back of the unit is a metal plate to which the speedometer/odometer assembly is attached. The plate is attached to the rest of the unit with six screws. You ask whether the screws must be encapsulated if the unit is to comply with S4.2.5.2. You also ask whether a seal that would have to be cut or torn in order to remove the plates and gain access to the odometer can be used.

Paragraph S4.2.5.2(b) of Standard No. 127 requires that a tamperer not be able to contact the odometer wheels by use of a straight rod .5mm or more in diameter. Such contact is permissible if the contact results when the rod is inserted essentially parallel to the odometer shaft, or if it is necessary either to penetrate the encapsulation or to damage the encapsulation or other odometer components to make that contact. Since your odometer/speedometer assembly is attached to the back plate, the odometer wheels can be easily reached from all angles without damaging the encapsulation when the plate is removed. Thus the screws must be encapsulated if the odometer is to comply with S4.2.5.2(b). If the screws are encapsulated in some fashion, it would be necessary to penetrate this encapsulation in order to remove the screws and the back plate, and the requirements of paragraph S4.2.5.2(b) would be satisfied.

Paragraph S4.2.5.2(d) sets forth the requirements for the encapsulation material. The rule specifies requirements for thickness and resistance to deflection, penetration, fracture, and impacts. The agency is not concerned about the form of the encapsulation as long as these requirements are met.

We hope you find this information helpful. Please contact this office if you have any further questions.

Sincerely,

Frank Berndt Chief Counsel

February 13, 1981

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street S.W. Washington DC 20590

RE: Request for Interpretation FMVSS 127 Speedometers and Odometers

Dear Mr. Berndt

This letter requests interpretation regarding compliance of an odometer which is part of a combination instrument unit and which BMW intends to use to meet the requirements of FMVSS 127, Speedometers and Odometers, as amended June 16, 1980, 45FR40585.

At a meeting with Messrs. Oesch, Parker and Carson on January 29, 1981, we showed subject unit and it was agreed that the odometer is totally encapsulated and falls under the requirements of S4.2.5.2(a)(1), (b), (c) and (d). The final closure technique, however, was subject to question.

As shown in the attachments 1, 2 and 3, the entire speedometer/odometer is a one-piece lens-top-bottom-sides unit, and plates are held on to the rear via screws. Based on our discussion, we request interpretation of the following questions:

1. At the meeting we showed a closure technique in which all six screws holding the rear plates are encapsulated with plastic caps, which must be broken to gain access to the screw heads (for demonstration purposes, see attached pictures showing only one screw encapsulated by the plastic cap). Accordingly, do the screws themselves holding the rear plates to the rest of the unit have to be encapsulated, such as with devices like these plastic caps?

2. In the event question 1 is answered affirmatively, we wish to know if it would be acceptable to use a seal, instead of the plastic caps discussed under question 1 (e.g. a self-destructing label) affixed to both the unit and the rear plates, in such a manner that the labels would have to be cut or torn in order to remove the plates to gain access to the odometer unit itself (see attachment 3).

Very truly yours

Karl-Heinz Ziwica, Manager Safety & Emission Control Engineering

KHZ/jps

Attachments

ID: nht81-2.12

DATE: 04/03/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Auto Meter Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

APR 3 1981

NOA-30

Mr. Rolan 'Jeep' Worthan National Sales Manager Auto Meter Products, Inc. 413 W. Elm Street Sycamore, IL 60178

Dear Mr. Worthan:

This responds to your letter of January 12, 1981, regarding the applicability section of Safety Standard No. 127, Speedometers and Odometers. You asked whether this standard applies to the speedometers you build, which are produced in low volume and primarily for manufacturers of show automobiles, off-road use vehicles and professional race cars. You interpret section S3 of the standard to apply only to "original equipment manufacturers such as Ford, General Motors or those who manufacture speedometers for them."

Your interpretation is not quite correct. As you note in your letter, the application section (S3) of Standard No. 127 states that:

This standard applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses, and to speedometers and odometers for use in vehicles to which this standard applies...

"Passenger car" is defined in S 571.3 of 49 CFR Part 571 as:

a motor vehicle with motive power, except a multi-purpose passenger vehicle, motorcycle, or trailer, designed for carrying 10 persons or less.

Thus, the word "passenger car" in Standard No. 127 encompasses more than those vehicles mass-produced by Ford, General Motors and Chrysler that we traditionally view as passenger cars. Any motor vehicle that (1) has motive power, (2) is designed to carry 10 persons or less (including the driver), and (3) that is not a multipurpose passenger vehicle (MPV), motorcycle, or trailer is a "passenger car."

Therefore, a professional racing car would be considered a "passenger car" if it is a "motor vehicle." Section 102(3) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) defines "motor vehicle" as:

any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

A motor vehicle is a vehicle which the manufacturer intends to be used on the public highways part of the time or has reason to expect will be so used. Vehicles intended and used solely for off-road use are not considered motor vehicles. Thus, a professional race car or show car that was built and is used solely for off-road purposes is not considered to be a motor vehicle under the Act. Vehicles which use the public roads on a necessary and recurring basis to move between work sites are classified as motor vehicles. However, in Koehring Co. v. Adams, 452 F. Supp. 635 (E.D. Wisc. 1978), aff'd., 605 F.2d 280 (7th Cir. 1979), the United States Court of Appeals for the Seventh Circuit held that mobile construction equipment that is used on the highways in such fashion does not fall within the definition of motor vehicle. The agency construes the opinion to apply only to the specific equipment at issue in Koehring Co., i.e., mobile cranes, mobile excavators, and mobile well drills.

Thus, the vehicles that you supply with speedometers may be considered "passenger cars" as the term is used in Safety Standard No. 127. We cannot make a definite determination on the basis of the information you have provided (you state that you supply speedometers primarily for off-road vehicles). However, the guidelines set forth above should enable you to reach your own decision. You should contact this office if you have questions about a specific vehicle. If the vehicles for which you are manufacturing speedometers are considered "passenger cars," Standard No. 127 would apply. However, since the speedometer provisions of this standard became effective on September 1, 1979, only speedometers (both original equipment and replacement) manufactured for passenger cars built on or after that date would have to comply. The speed indicator scale on such a speedometer would have to be limited to 85 mph. The Act does not give this agency the power to grant manufacturers of motor vehicle equipment exemptions from applicable safety standards on the grounds of low volume.

We hope you find this information helpful. Please contact this office if you have any more questions.

Sincerely,

Frank Berndt Chief Counsel

January 12, 1981 Office of the Chief Counsel NOA-30 N.H.T.S.A. 400 7th Street SW Washington, D.C. 20590

Dear Sir:

Auto Meter Products Inc. is an aftermarket manufacturer of specialty and hi-performance instruments. Among the instruments that we manufacture and for which I am concerned at this time, are speedometers. We have become aware of recent regulations limiting standard speedometers to 85 MPH maximum and are interested in your confirmation of our interpretation of this regulation.

On page 40593 in Standard No. 127 of the Federal Register volume 45, covering speedometers and odometers, the application of this regulation, (S-3) states, "This standard applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses, and to speedometers and odometers for use in vehicles to which this standard applies." In reading over regulation 127, I interpret the standard to be referring to original equipment manufacturers such as Ford, General Motors or those who manufacture speedometers for them. That these standard OEM speedometers are limited to go no higher than 85 MPH.

Since Auto Meter Products Inc. speedomters are produced in low volume and are used primarily in show automobiles, off road use, professional race cars etc. rather than street applications, it is our uderstanding that the 85 MPH limit of the standard No. 127 does not apply. Please advise.

Sincerely,

Rolan 'Jeep' Worthan National Sales Manager

RJW/ap cc: B. Owens

ID: nht81-2.13

DATE: 04/07/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Meadowood Management Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of February 5, 1981, in which you seek help in defining the terms "van," "motor home," "recreational vehicle," and "motor coach."

The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards which are applicable to motor vehicles or motor vehicle equipment. Our regulations do not specifically define the terms you use in your letter. Rather, the agency's regulations establish generic categories such as "passenger car," "truck," "trailer," "bus," and "multipurpose passenger vehicle." These terms are defined in 49 CFR @ 571.3 (copy enclosed). A particular vehicle may fall into one or another category depending upon its design and use. For example, a "van" may be either a "bus," "multipurpose passenger vehicle," or a "truck," depending upon the number of designated seating positions and the use of the vehicle.

The Recreation Vehicle Industry Association, P.O. Box 204, 14650 Lee Road, Chantilly, Virginia 22021, or The Society of Automotive Engineers, Inc., 400 Commonwealth Drive, Warrendale, Pennsylvania 15096, may be able to provide you with specific definitions.

Please contact this office if you have further questions.

Sincerely

ATTACH.

FEBRUARY 5, 1981

Motor Highway Traffic Safety Administrator Department of Transportation

Dear Sir:

Our Community Association, like many others, has restrictions that apply to different types of vehicles. The problem common to all such Associations is how to distinguish the types of vehicles. The confusion arises out of contradictions of definitions as between manufacturers certifications and license bureaus, and even between license bureaus. The problem is the hybrid types of vehicles now being marketed.

We will appreciate any assistance you can give us in defining the following types of vehicles:

A. Vans B. Motor Homes

C. Recreational Vehicles

D. Motor Coaches

Thank you for your time.

Sincerely,

Roger F. Dunn -- Manager, MEADOWBROOK MANAGEMENT COMPANY, INC.

ID: nht81-2.14

DATE: 04/14/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Seats Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 20, 1981, letter asking about the seat belt testing requirement applicable to seat belts mounted on a seat frame in a school bus.

You state that it is your understanding that seat belts that are mounted on a seat frame in a school bus are not required to be tested simultaneously, because the seat is not considered to be a common mounting. Further, you state that if the seat belts mounted on the frame use a common anchorage, either a common anchorage hole or a U-bolt connecting the two belts, that they would be required to be tested simultaneously.

Your interpretation of Standard No. 222 as it relates to school buses is correct. We would emphasize that this interpretation for the testing of seat mounted seat belts applies only to school buses.

SINCERELY,

Seats

March 20, 1981

Mr. Frank Berndt U.S. Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Berndt:

Reference: NOA-30

As a final effort to end all misinterpretations of your Department's stand on FMVSS 222, School Bus Passenger Seating and Crash Protection, seat belt requirements; I reference past communication with your department, copies enclosed, on the subject of common and separate mounting and the effect a U-bolt mounting has on the Department's interpretation to common mounting and test requirements. Communications referenced are:

A. Your Department's interpretation to Wayne Corporation, dated March 25, 1977 (Enclosure A)

B. Letter to Mr. Roger Tilton, dated October 31, 1980 (Enclosure B)

C. Your Department's letter NOA-30, dated December 2, 1980 (Enclosure C)

I understand, in layman's language, so all can have, without doubt, the same understanding of the following, that individual seat belt anchorage testing is required as long as each seat belt system has its own anchorage points.

Therefore, the simultaneous testing is totally dependent on the interpretation of common anchorage of two seat belt systems on a two-passenger seat assembly.

It is further my interpretation that the metal seat frame or supporting structure is not considered a common anchorage point, that each seat belt system being attached to the seat frame by its own bolts and nuts, one set for each end of the seat belt system, is not considered common anchorage; and therefore, does not require simultaneous testing of the two seat belt systems, but independent tests of 5,000 pounds. However, if any part of the two seat belt systems are attached by a single bolt and nut on the inside portions or the use of a U-bolt so that the same attaching hardware comes in contact with more than one seat belt system, it is considered a common anchorage point and thus requires simultaneous testing of 5,000 pounds for each seat belt system for a total force of 10,000 pounds.

If you concur with my interpretation on this matter, please sign one copy in the space provided and return to me for my records file.

Harold J. Van Duser Engineering

Mr. Frank Berndt U.S. Department of Transportation

ID: nht81-2.15

DATE: 04/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Rivkin, Sherman and Levy

TITLE: FMVSR INTERPRETATION

TEXT:

APR 16 1981 NOA-30

Donald M. Schwentker, Esq. Rivkin, Sherman and Levy 900 17th Street, N.W. Suite 1100 Washington, D.C. 20006

Dear Mr. Schwentker:

This letter is in reference to our March 20, 1981, meeting with you and your client, Jaguar. The meeting was held at your request and concerned whether future product plans of Jaguar are consistent with existing Federal motor vehicle safety standards.

As we indicated to you at the beginning of the meeting, the agency does not give oral interpretations. The agency holds such meetings with industry representatives in order to help those representatives identify questions which should be submitted in writing to the Office of Chief Counsel for interpretation, and to familiarize agency personnel with the specific nature of products at issue.

One concern expressed by Jaguar in that meeting was the confidentiality of its future product plans. In issuing letters of interpretation, the agency ordinarily will provide confidential treatment for future product plans. A request for confidential treatment should accompany the request for interpretation. The agency published a final rule concerning confidential business information in the Federal Register (46 FR 2049) on January 8, 1981. While that rule is not yet effective, we suggest that its procedures for requesting confidential treatment be followed. We would note that even where the agency provides confidential treatment for future product plans, letters of interpretation issued by the agency are made available to the public for inspection. In drafting a letter of interpretation, only the information necessary for that interpretation would be stated. The agency does not issue private letters of interpretation, however. During the March 20 meeting, you indicated that Jaguar might find it preferable not to request an interpretation in light of its concerns about confidentiality. We would like to remind you that informal discussions with agency personnel should not be relied on as evidence that the agency approves of stated product plans or that those plans comply with Federal motor vehicle safety standards. Moreover, the fact that particular issues concerning compliance with Federal motor vehicle safety standards were not raised at the March 20 meeting should not be taken to mean that such issues do not exist. Sincerely, Frank Berndt Chief Counsel

ID: nht81-2.16

DATE: 04/22/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: PolyDyne Engineering

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. O. Vandewege, President PolyDyne Engineering Box 3517 Scottsdale, Arizona 85257

Dear Mr. Vandewege:

This responds to your letter of March 6, 1981, to Joseph Zemaitis, Motor Vehicle Program Director, Region IX, regarding Safety Standard No. 125, Warning Devices. You wish to obtain approval of your warning device (the "short stop") for use on trucks and trailers. Your device is a collapsible reflective triangle that is designed to be permanently mounted on the side or rear of a vehicle.

The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), authorizes the National Highway Traffic Safety Administration to issue Federal motor vehicle safety standards which are applicable to motor vehicles or motor vehicle equipment. Safety Standard No. 125, Warning Devices, establishes requirements for devices that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle. The rule does not apply to warning devices that are designed to be permanently affixed to the vehicle, and thus does not apply to your device. Hence, it is not necessary for you to obtain the "approval" of this agency before you may manufacture or sell a "short stop" or before an owner may use such a warning device on his vehicle.

However, the Federal Highway Administration (FHWA) has promulgated a regulation (49 CFR S 393.95) regarding the use of emergency equipment on heavy duty trucks and buses that are used in interstate commerce. This standard may prohibit the use of warning devices such as the "short stop" on certain types of vehicles. Since the FHWA can best address this issue, we have forwarded your letter to that agency's Chief Counsel for response. The address of that office is Room 4213, 400 Seventh Street, S.W., Washington, D.C. 20590.

We hope you find this information helpful. Please contact this office if you have any questions.

Sincerely,

Frank Berndt Chief Counsel

ID: nht81-2.17

DATE: 04/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: N. B. Echelberry

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the vehicle owner's questionnaire you forwarded on March 9, 1981, concerning the installation of computer terminals in patrol cars assigned to the city of Miami Police Department. The questionnaire was recently forwarded to my office for reply. You asked whether the installation violated any safety standards.

Federal Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact, a copy of which is enclosed, specifies performance requirements for the instrument panel. It can't be determined from the information you provided whether the terminals are located within an area of the vehicle covered by that standard. The standard generally regulates only the upper portion of the dashboard. If it is located within the regulated zone, the installation of the computer terminal on the vehicle's instrument panel may be affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (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 part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . .

Modification of the instrument panel by a manufacturer, distributor, dealer or motor vehicle repair business during the installation of the computer terminals so that it no longer complies with Standard No. 201 would be a violation of section 108(a)(2)(A).

If you have any further questions, please let me know.

DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION VEHICLE OWNER'S QUESTIONNAIRE

HL NO.: (Illegible Words)

OWNER

LAST NAME: ECHELBERRY FIRST NAME & MIDDLE INITIAL: NORMAN B. TELEPHONE NO. (Area Code): Work- 579-6540 Home- 579-6111

STREET ADDRESS: 2514 SHERMAN ST. CITY: HOLLYWOOD STATE: FL. ZIP CODE: 33020

VEHICLE INFORMATION

VEHICLE MAKE & MODEL: PLYMOUTH VOLARE MODEL YEAR: 79-80 BODY STYLE: 4 DR. VEHICLE IDENTIFICATION NO.: UNK.

ENGINE SIZE (CID/CC): UNK. [X] GAS [] DIESEL MILEAGE: UNK DATE PURCHASED: [X] NEW [] USED DEALER'S NAME AND ADDRESS: AIR CONDITIONED: [X] Yes [] No

VEHICLE SPEED AT FAILURE: [] Parked NO. CYLINDERS: 8 POWER STEERING: [X] YES [] NO POWER BRAKES: [X] YES [] NO TRANSMISSION MANUAL (Speed): AUTOMATIC [X] Yes [] No [] 3 [] 4 [] 5 TYPE

FAILED COMPONENT/PART INFORMATION

COMPONENT/PART NAME: LOCATION: [] Left [] Right [] Front [] Rear FAILED PART: [] Original [] Replacement MILEAGE AT FAILURE: NO. OF FAILURES:

DESCRIPTION OF FAILURE: (OVER)

FAILED TIRE INFORMATION

MANUFACTURER: TIRE NAME: SIZE: TYPE FAILURE:

CONSTRUCTION: [] Belted [] Bias [] Radial FAILED TIRE: [] Original [] Replacement BELT MATERIAL: [] Steel [] Fiberglass [] Aramid [] Rayon LOCATION: [] Right Front [] Right Rear [] Left Front [] Left Rear [] Spare DOT IDENTIFICATION NO. *:

* The identification number consists of about ten letters and numerals following the letters DOT usually located near the rim flange on the side opposite the whitewall or on either side of a blackwall tire.

APPLICABLE ACCIDENT INFORMATION

ACCIDENT: [X] Yes [] No NO. INJURIES: UNK.- INFO NOT AVAILABLE NO. FATALITIES: 0

DESCRIPTION OF ACCIDENT: OVER SIGNATURE OF OWNER: (Illegible Words) DATE: 2-20-81

DESCRIPTION OF PROBLEM

I am employed by the City of Miami Police Dept.-400 NW 2 Ave Miami, Fl. Currently, nearly our entire fleet of patrol cars have had computer terminals installed in them. These terminals are approx. 12" x 12" x 18" high. They protrude from the center dashboard into the area over the front seat. Two thin metal brackets support this terminal. There have been accidents where our officers were injured as a result of this installation. I have made several inquiries to different agencies to determine if this is indeed a violation of a safety standard. I received your agencies name to send a request to.

Please respond if I have contacted the wrong agency. This is a serious matter, particularly for passengers in the front right side. These items are going to be installed in vehicles due for a near future delivery.

Thank you for your attention on this matter.

(Illegible Words)

ID: nht81-2.18

DATE: 04/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Weinblatt & Knee

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 5, 1981, in which you requested a copy of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials. You are apparently trying to determine what types of glazing material may be used in "caps" installed on truck bodies.

Safety Standard No. 205 specifies performance requirements for glazing materials to be used in motor vehicles and motor vehicle equipment. The standard incorporates by reference the American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways," Z26.1-1966 (ANS Z26). Copies of both standards are enclosed. ANS Z26 and Standard No. 205 list 13 "Items" or types of glazing that vary in terms of the performance tests each item must pass and the locations in which each type of glazing may be used. While the meaning of the word "cap" as used in your letter is somewhat unclear, we presume you are referring to a "pickup cover." A "pickup cover" is defined in paragraph S4 of Standard No. 205 as a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user. All 13 items of glazing may be used in pickup covers. However, some items (e.g., Item 6) may not be used in forward-facing windows, and others (e.g., Item 5) may not be used at levels requisite for driving visibility.

Certification and marking requirements for glazing are found in paragraphs S6.4 and S6.5 of Standard No. 205.

We hope you find this information helpful. Please contact this office if you have any further questions.

Sincerely,

ATTACH.

March 5, 1981

U.S. Department of Transportation -- Attn: Regulatory Division

Gentlemen:

I have been informed by a client that there is a Federal regulation promulgated by your Department requiring a certain safety stamping with a number of every peice of glass or plastic substitute for glass used on any auto, truck, camper, cap, etc.

I would greatly appreciate a copy of that regulation since it involved a legal question as to what my client is allowed to install as part of his business of selling caps that go on truck bodies.

Thank you for your immediate attention in this matter.

Very truly yours,

SEYMOUR S. WEINBLATT -- WEINBLATT & KNEE COUNSELLORS AT LAW

ID: nht81-2.19

ID: nht81-2.2

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sutphen Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Robert L. Poe General Manager Sutphen Corporation 7000 Columbus-Marysville Road P.O. Amlin, Ohio 43002

Dear Mr. Poe

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

November 19, 1980

National Highway Traffic Safety Administration Subject: Submittal of Vehicle 407th Street, S.W. Identification Number (VIN) Washington, D.C. 20590 Application Breakdown

Attention: Vin Coordinator Gentlemen:

Please find, enclosed, a copy of the Sutphen Corporation forms which will be utilized in assigning VIN numbers to apparatus manufactured after February 1, 1981.

It is assumed that submittal of these tabulations are satisfactory to fulfill our requirements as applicable to FMVSS 115 (amended).

If further information is needed, please contact the undersigned.

Very truly yours,

ROBERT L. POE General Manager

rs enc.