Interpretation ID: nht75-3.8

DATE: 09/16/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Hardy Heater Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 30, 1975, in which you inquire as to any rules and regulations to which you may be subject with respect to your pre-heater defroster. Your letter was referred to this office by the Environmental Protection Agency.

We assume, from the material submitted with your letter, that your pre-heater is sold for installation in used cars and supplements the vehicle's existing defrosting system. If our assumption is incorrect, please advise us. If your pre-heater is installed in a motor vehicle prior to its first purchase or if it replaces an existing defrosting system, you will be subject to regulations in addition to those mentioned in this letter.

The National Traffic and Motor Vehicle Safety Act provides that a manufacturer, dealer, distributor, or repair shop may not render inoperative any safety device or design in a motor vehicle after its first purchase by the owner. This means that the installation of the pre-heater must not take the vehicle out of compliance with an applicable Federal Motor Vehicle Safety Standard. The standard with which you will likely be most concerned is Standard No. 103, Windshield Defrosting and Defogging Systems (copy enclosed).

(Graphics omitted)

In addition, if the fuel used in your pre-heater has a boiling point greater than 32 degrees F, you must ensure that the pre-heater fuel system complies with Standard No. 301, Fuel System Integrity (copy enclosed).

Thank you for your interest in motor vehicle safety.

YOURS TRULY

THE HARDY HEATER COMPANY

July 30, 1975

Director E. P. A.

I am having manufactured and will market a pre-heater defroster for auto's as shown in the attached documents which are a part of my (Illegible Words).

Please advise me if I am required by rules, regulations or otherwise to obtain any (Illegible Word)) permits to prior to marketing my heater nationwide.

As you (Illegible Words) cylinder of L. P. (Illegible Words) am primarily concerned with any legal requirement with respect its use in automobiles.

I will appreciate any information on the subject.

Frank Hardy

Teddy's drivers in cold climates are not satisfied each day entering a miserably cold auto, with limited or no vision because of condensation, frost, ice, snow, build-up on the glassed areas.

A majority of the over 80 million cars on our highways, and the over 10 million being built each year, need this heater to provide a warm, safe comfortable car from the start. This device fills a gap that has been completely overlooked in automotive engineering.

Please note how many vehicles you see on the highway, especially in the morning, in cooler climates, driving virtually blind, until the standard heater defroster clears the glass area. My heater eliminates this dangerous condition, and provides a comfortable temperature inside the car from the start.

A common cold weather practice is to start the auto engine on cold mornings and let it set and run until the conventional heating process warms and defrosts the car. This practice causes excessive engine wear and long periods of cold engine idle, which is a major factor in air pollution by automobiles. This inconvenience, wear, and pollution can be eliminated with the use of my heater.

Volume sales will be to gasoline powered vehicles; however, it will be a natural as an inducement for all who are thinking of conversion or have converted to propane from gasoline as a motor fuel, as certain basic components such as fuel tank controls, etc., could serve both installations.

Attached is information on a unique gas fired auxiliary and independent automobile heater, that will eliminate the misery and danger of a cold automobile, with frosted glass area, when you first enter it in cold weather. It can provide home-like comfort 24 hours a day, or may be shut off to automatically come on several hours before returning to the car, at which time it will be heated and frost free for safe and comfortable driving from the start.

I have a patent pending for this heater, and am interested in working with a manufacturer for mutual benefits in the production and sale of this item.

I am available for an interview to discuss any ideas or interest you might have concerning my situation.

Warren Frank Hardy

(Graphics omitted)

(Graphics omitted)