Interpretation ID: nht69-1.42

DATE: 06/17/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Gruman Allied Industries Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in further response to your letter dated April 9, 1969, addressed to Robert M. O'Mahoney, which has been referred to this Bureau.

The location you have selected on the windshield wiper motor bracket, as shown in your enclosed drawing number 69028, sheet 2, is approved as an alternative to the specified locations. We note, however, that you intend to use binding-head screws as your method of attachment. This method does not appear to fulfill the requirements of permanency and destruction on removal in section 367.4(b) of the Certification Regulations, 49 CFR Part 367.

As issued January 24, 1969 (34 F.R. 1148) the above section reads: "The label shall be permanently affixed in such a manner that it cannot be removed without the use of tools and without destroying it." A proposal issued on April 29, 1969 (34 F.R. 7032) would amend the section to read: "The label shall be permanently affixed in such a manner that it cannot be removed without destroying it." The requirements of permanency and destruction on removal remain in both versions.

Your cooperation is appreciated.