Interpretation ID: nht93-8.38

DATE: November 30, 1993

FROM: Len R. Thies -- C & C Creations

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/18/94 From John Womack To Len R. Thies (A42; Std. 111; Std. 205; Std. 302)

TEXT: Dear Mr. Womack:

My partner and I have developed an after-market device for use in commercial and non-commercial vans. The device inhibits the flow of air from the back of the van to the front and vice-versa, in effect reducing the amount of volume to be heated or cooled. The result is a more efficient use of the vehicle's heating/cooling system resulting in more comfort for the driver and passengers especially in cases of extreme temperatures.

The device is composed of a sheet of clear vinyl suspended near the ceiling by a metal bar. The vinyl is also attached to the sides of the vehicle by velcro patches. Visibility is unimpaired, and is easily detached and removed from the vehicle by the owner.

After additional testing we intend to start marketing the device. In order to address all potential regulations, I contacted Ms. Mary Verseilles and Mr. Mark Levine in your office, who have given me their informal opinions. I appreciate their time and commend them for their sincerity in addressing my questions and for guidance through other potential areas of concern.

The only real concern regarding the device is one raised by Mr. Levine and focuses on fire resistence. Vinyl will burn but must have constant ignition in order to do so. Many people might call it a "melt" rather than a burning action.

Basis the foregoing I would request from you a written opinion relative to the acceptability of the device for use in vehicles.

Thank you in advance for your handling of my request.

Sincerely,