Interpretation ID: nht75-4.24

DATE: 07/22/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: RVIA

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 22, 1975, in which you request an interpretation which excludes roof vent covers in recreational vehicles from the coverage of Motor Vehicle Safety Standard No. 205.

The National Highway Traffic Safety Administration (NHTSA) has received an identical request from Richards, Watson, Dreyfuss & Gershon on behalf of Hehr International, Inc. In response to that request, we have determined that roof vent covers should be included within the scope of Standard No. 205, but also concur that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures found in USAS Z26.1. Consequently, we intend to issue in the near future proposed rulemaking which would establish surrogate testing procedures for this type of roof vent cover. Until such time as the new procedure is adopted, it is the intention of the NHTSA to take no action against manufacturers who do not certify that their injection molded roof vent covers meet the requirements of Standard No. 205 which incorporate the requirements of USAS Z26.1.