Interpretation ID: nht79-3.16

DATE: 11/14/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Performance Plus Products, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the questions that you raised on October 23, 1979, with Ms. Debra Weiner of my office concerning the legal and technical issues arising from the manufacture of auxiliary fuel tanks for use in pickup trucks. You noted that you are going into the business of manufacturing auxiliary fuel tanks, that you will not be involved in the installation of such tanks, and that you would like any advice that we might be able to provide as to the construction standards that should be followed in manufacturing such tanks.

I have enclosed a copy of a letter which was sent to a company that planned to manufacture auxiliary fuel tanks for passenger cars and to do some installation. The legal principles enunciated in that letter are applicable to auxiliary fuel tanks intended for use in all types of motor vehicles except motor carriers in interstate commerce. Although your company is not planning to install auxiliary tanks, I think that you might find that the discussion of the legal issues that arise with respect to installation may be helpful in determining what safety margins should be built into these types of tanks.

As Ms. Weiner noted on the phone, this agency has not issued any standards applicable to the construction of auxiliary fuel tanks. However, the Federal Highway Administration, Bureau of Motor Carrier Safety has issued standards relevant to the construction of auxiliary fuel tanks for use in motor vehicles which are engaged in interstate commerce. I have enclosed a copy of these standards in hope that they will provide you with some suggestions as to what would constitute safe construction of an auxiliary fuel tank. In addition, the Society of Automotive Engineers has published standards pertinent to some aspects of the construction of fuel tanks. I have also enclosed copies of these.

I hope that you will find the enclosed material helpful. If you have any further questions, please feel free to contact Ms. Weiner for further information.