Interpretation ID: nht94-6.25

DATE: April 18, 1994

FROM: Fred Benford -- 100+ Motoring Accessories

TO: John Womack -- Acting Chief Counsel, NHTSA

COPYEE: Russ Fuller; Everett Fuller; Cliff Cook

TITLE: None

ATTACHMT: Attached To Letter Dated 5/16/94 From John Womack To Fred Benford (A42; Std. 211)

TEXT: Dear Mr. Womac:

The Chief Counsel of the Specialty Equipment Manufacturers Association (SEMA) reviewed all regulations covering wheel covers and suggested that we contact Mr. Truman Vincent. We explained our situation to Mr. Vincent who in turn, suggested that we address our request to your attention.

We are a manufacturer of Aluminum Wheel Covers. They are a standard type and do not have any protrusions (e.g., spinners, etc.). With the assistance of the Chief Counsel at SEMA, the current regulations were reviewed and it was determined that our Aluminum Wheel Covers are similar in design to the Steel and ABS plastic type and are not covered by any regulations, except for # 211 which prohibits protruding objects such as spinners, etc. Our wheel covers do not have any protruding objects.

At the current time, we are the only manufacturers of Aluminum Wheel Covers. Because they are made of a different material from the current steel and ABS models, a major retailer has asked us to confirm that aluminum, like the ABS and Steel wheel covers, do not violate any federal safety standards. Considering information from our SEMA counsel, and Mr. Truman Vincent, we do indeed not violate any federal safety standards. However, the major retailer (and possibly others) has requested a confirmation in writing from the Department of Transportation. We would appreciate a statement from you with wording to this effect to present to the retailer.

Thank you for your assistance. We would appreciate hearing from you quickly. If desired, you may fax your response to the phone listed below.

Sincerely,