Interpretation ID: nht74-5.51

DATE: 04/18/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Law Ofices of William and Black

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 29, 1974, requesting information and documentation concerning Fuel System Integrity Standards.

The GSA 515/26 Standard which you mentioned was published July 15, 1966, and was effective October 13, 1967. This standard was effectively supplanted by Federal Motor Vehicle Safety Standard No. 301 which was effective January 1, 1968. A copy of this original Standard No. 301 is enclosed for your information along with a recent amendment (F.R. 39, 10586, March 21, 1974) that substantially upgrades the requirements of this standard.

We do not consider it appropriate to give advice concerning private incidents or controversies, beyond what is contained in our regulations and other public issuances. You may find it helpful to contact private-sector groups such as the Society of Automotive Engineers for further information.

ENC. (3)

Williams and Black

March 29, 1974

Department of Transportation National Highway Traffic Safety Administration OFFICE OF CRASHWORTHINESS

Attention: Guy Hunter

Re: KLANN vs. FORD MOTOR COMPANY

I had a very lengthy conversation with Mr. Koschak in the Los Angeles Office of the General Services Administration. He very kindly referred me to you for help needed in this matter.

We presently have an action pending against the Ford Motor Company for the deaths of two adults following a collision while they were driving a 1965 Model P-250 pick-up truck. This pick-up truck had a camper installed on the bed.

The accident would be a barrier-type crash in which a vehicle went out of control on the opposite side of the road, came into the lane of the subject vehicle and the crash ensued.

The husband and wife occupying the pick-up truck were burned to death. We have had several experts examine this vehicle and have described the mechanism of their incineration as a shearing of the neck of the gas-tank filler pipe, along with some displacement of the cab of the vehicle itself. Between the shearing of the neck, as well as the displacement, the fuel in the tank was forced into the driving compartment, and a fire of great intensity developed.

This fire was of sufficient intensity to melt the interior fittings of the vehicle, as well as causing fatal injuries to the occupants.

During the process of our litigation with Ford Motor Company, we have had occasion to examine, but not photocopy certain of their crash tests. These crash tests make reference to a publication specifically referred to as "1968 GSA Standard 515/26-53.2." This reference was contained in test No. D-5192 performed on October 15, 1966. This was a sixteen mile per hour crash into a movable barrier. I further note that in one of the additional tests, more particularly, No. D S126 performed on August 5, 1966, which was a 29.5 m.p.h. crash into a barrier, the test results indicated that the fuel tank displaced; however, no photos of the crashed vehicle were attached to the Ford test.

We are interested in learning the specifications or directions from the Department of Transportation to auto manufactuers and, more particularly, as relates to the fuel systems and locations in 1965 and 1966 model vehicles -- i.e., pick-up trucks. We would also like to know whether or not the Department of Transportation directed any recall or modification campaigns, either by direction or by suggestion to the automobile manufacturers, especially Ford Motor Company.

We have been advised by our own automotive engineers that the location of the gasoline tank is a defect in design. We believe that our position would be further fortified by some communications or directions from the Department of Transportation directed to the various automobile manufacturers as relate to the location or stability of gasoline tank systems.

I am uncertain as to what we are looking for is adequately described within this letter; however, I believe the brief description I have given may be sufficient for you to determine specifically what we are looking for.

We would certainly appreciate any copies of correspondence or any other documents you may have as pertains to this problem and, more particularly, communications directed to the Ford Motor Company referring to their fuel system in their pick-up trucks.

Thanking you in advance for your anticipated courtesy and cooperation, I remain,

ROBERT S. PRIVER

cc: Mike Koschak c/o General Services Administration Motor Pool 300 North Los Angeles Street, Suite 3124 Los Angeles, California 90012