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Interpretation ID: nht73-5.18

DATE: 03/29/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. R. W. Lillie

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 30, 1973 and our sincere apologies for the delay in responding to your letter.

There are no Federal Motor Vehicle Safety Standards applicable to plastic fuel tanks. Standard No. 301, which includes the fuel tank in the(Illegible Word) performance requirements of the vehicle, makes no reference to the construction or design details of the fuel tank. A booklet briefly describing the issued standards is enclosed.

The Department of Transportation does not routinely receive and test fuel tanks of the various manufacturers; however, the Department keeps abreast of technical advancements of these companies through technical society meetings and trade journals. It has been brought to our attention that Dow Chemical Company has done considerable work with high density polyethylene fuel tanks and offers an internal treatment of these tanks which is claimed to reduce considerably the permeation of gasoline through the walls. Further information may be obtained from the following source:

Dow Chemical U.S.A. Plastics Department Midland, Michigan 48640

Standard No. 116 is applicable to Hydraulic Brake Fluids and is included in the consolidated edition of the Federal Motor Vehicle Safety Standards and Regulations, as per the enclosed order form.

2

The physical characteristics and labeling requirements of brake fluids, including silicones, are included in this standard, a copy of which is enclosed for your information. Your inquiry concerning the use of silicones in automobiles can best be answered by the Original Equipment Manufacturers or the automotive companies. The interest of the Department in materials is primarily performance rather than design considerations, for example, an(Illegible Word) material could be silicone, neoprene or ether(Illegible Word) as long as the standards are complied with.

The Bureau of Motor Carrier Safety has issued standards that are applicable to commerical vehicles engaged in interstate commerce, and some of these standards apply to fuel tanks. A portion of these regulations that pertains to fuel tanks is also enclosed for your information, along with an Advance Notice of Proposed Rule Making that concerns plastic fuel tanks (F. R, Vol. 36, No. 178, September 14, 1971). Additional information is available from the Bureau of Motor Carrier Safety Federal Highway Administration, 400 Seventh Street, S. W., Washington, D.C. 20590.

5 ENCLS.

R. W. LILLIE & COMPANY

January 30, 1973

United States Department of Transportation National Highway Traffic Safety Administration

Dear Sir:

Your reply doesn't answer our questions. How do we get those which are not in NHTSA standards?

Very truly yours,

R. W. Lillie

(Illegible Word)

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION WASHINGTON, D.C. 20590

In reply refer to N48-51

Thank you for your inquiry regarding the Federal Motor Vehicle Safety Standards. The standards are not available from the NHTSA, but may be purchased from the Superintendent of Documents on a subscription basis. An order form is enclosed for your convenience.

R. W. LILLIE & COMPANY

December 8, 1972

United States Department of Transportation

Dear Sir:

We are aware that certain efforts have been underway aimed at the use of plastic fuel tanks for autos. We would like to know the status of these developments, and since we are sure DOT is involved in testing and/or approval procedures, we would appreciate any reports you can send us on this subject: Such matters as the following would be of interest, as well as any othermatters influencing the ultimate use of these tanks:

1. Tests that must be met to receive DOT approval

2. Results of tests on any tanks already submitted

3. Indications of which polymers may be suitable

4. Other interesting information.

We would also like to receive a copy of the NHTSA Regulation concerning the use of brake fluids for automobiles. We are also looking for any other information you may have on the use of silicones in automobiles.

Thank you very much for your assistance.

Very truly yours,

R. W. Lillie