Interpretation ID: nht70-2.18

DATE: 08/11/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: University of Michigan Law School

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of June 22, 1970, concerning the Cyromatic Safety Control, together with a copy of the July 1, 1970, reply sent by Mr.(Illegible Word) Weinberger, Chairman of the Federal Trade Commission, has been referred to my office for reply.

The National Highway Safety Bureau does not have the facilities for testing or investigating specific devices or designs. However, the(Illegible Word) on Winter(Illegible Words) of the National Safety Council has completed an(Illegible Words) of the type mentioned in your letter. I am enclosing for your information a copy of the National Safety Council report on this evaluation.

In brief, the conclusion of the Committee were that there were no significant differences in the performance of the test vehicles whether the device was stated and operable, rendered inoperable, or removed from the vehicles. The only test results considered significant involved a high(Illegible Words) on dry pavement where the device increased(Illegible Words) of the test vehicles by a substantial amount, thus effecting their handling performance adversely.

It is felt that sufficient date is available in the National Safety Council Committee on(Illegible Words) evaluation to warrant investigation on the(Illegible Words) on the Federal Trade Commission, concerning possible misleading advertising on the part of manufacturers of this type of device. Consequently, we have contacted, Mr. Weinberger directly concerning the(Illegible Words).