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Interpretation ID: nht80-1.12

DATE: 02/08/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Brotherhood Racing

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your conversation with Mr. Hugh Oates of my office concerning the manufacture and installation of replacement fuel tanks.

Enclosed please find (1) a copy of a letter concerning the legal implications of replacing a vehicle's fuel tank with a larger tank, (2) a copy of a letter concerning the legal implications of building and installing auxiliary fuel tanks which discusses issues also relevant to replacement fuel tanks and (3) a notice describing how to obtain copies of motor vehicle safety standards and regulations.

In addition to the points raised in the enclosed letters, I would like to point out two additional factors. First, please note that if you go into the business of manufacturing replacement fuel tanks you must submit identifying information and a description of the items you produce to this agency in accord with 49 CFR Part 566 (copy enclosed).

Second, as you will note from the enclosed letters, a manufacturer or other person specified in the National Traffic and Motor Vehicle Safety Act who installs an auxiliary or replacement fuel tank in a new or used vehicle must not compromise the vehicle's compliance with relevant safety standards. Thus, in installing replacement fuel tanks you should be aware not only of any effect that your installation may have upon the vehicle's fuel system (see Federal Motor Vehicle Safety Standard 301-75, Fuel System Integrity), you should also be aware that your installation might affect, among othert things, the vehicle's braking system (see Safety Standard No. 105-75, Hydraulic Brake Systems) or the vehicle's weight as it relates to safety standards concerning tires (see Safety Standard No. 110, Tire Selection and Rims, applicable to passenger cars, and Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars).

I hope that you will find the enclosed material helpful. If you have any further questions, please feel free to call Ms. Debra Weiner of my office at 202-426-2992.

ENCLS.