Interpretation ID: nht72-5.23

DATE: 11/22/72

FROM: ELWOOD T. DRIVER FOR ROBERT L. CARTER -- NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 22, 1972, proposing that the "Certification" regulations (49 CFR Part 567) be amended to allow the use of "metal stamping or embossed letters" for information which must be inserted on certification labels.

We have treated your request as a petition for rulemaking persuant to 49 CFR Part 553, and have decided that it should be denied. The NHTSA is of the view that numbers and letters added in this way are frequently difficult to read. To allow their use as you have (Illegible Word) would be inconsistent with the purpose of the Certification regulations that the relevant information be provided to (Illegible Word) in as easily legible manner.

There is no prohibition, of course, of the use of stamped or embassed lettering on labels if steps are taken to make it contrast with its background.