Interpretation ID: nht81-1.28

DATE: 03/05/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Smith Industries Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. W. W. Bischoff Divisional Technical Director Smith Industries Limited Vehicle Instrumentation Division Cricklewood Works, London, England NW2 6NN

Dear Mr. Bischoff:

This responds to your letter of January 28, 1981 to John W. Carson regarding Safety Standard No. 127, Speedometers and Odometers. You asked whether the encapsulation requirements of this standard (S4.2.5.2) are satisfied if a speedometer is housed in a metal case and sealed by a window and a spun-over metal bezel.

The National Highway Traffic Safety Administration (NHTSA) does not offer prior approval of compliance of any vehicle or equipment design with any safety standard before the manufacturer's certification of its product. It is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. S1381 et seq.) to determine whether its vehicle or equipment complies with all applicable safety standards and regulations and to certify its vehicle or equipment in accordance with that determination.

The agency is willing to offer an opinion on whether a vehicle or motor vehicle equipment complies with a particular rule. Such an opinion is not binding on the agency or on the manufacturer. However, the information you have provided in your letter does not give us a sufficient basis on which to form an opinion. We must see the equipment in question, or at least pictures or drawings of the equipment design, to render a judgment.

Please contact this office if you have more questions.

Sincerely,

Frank Berndt Chief Counsel

28th January 1981

Mr. John W. Carson, Office of Vehicle Safety Standards, N.H.T.S.A. 400 Seventh Street SW Washington DC 20590

Dear Sir,

Re: FMVSS 127, Speedometers and Odometers Final Rule (Docket 76-06, Notice 9)

Please advise by return whether the odometer tamper resistant requirement is satisfied relative to the 'Access to the odometer requirement', for a speedometer housed in a metal case and sealed by a window and spun over metal bezel.

Thank you.

Yours truly, for: Smiths Industries Limited

W.W. BISCHOFF Divisional Technical Director