Could old Henry Ford's 1928 Model A roadster pass today's federal motor vehicle safety standards?

The question is not as hypothetical as it seems, according to the Aug. 4 Federal Register (page 51700).

A Michigan company went into business two years ago to produce replicas of the Model A. It had to ask the National Highway Traffic Safety Administration in 1979 for an exemption from seven of the federal regulatory standards established under the Traffic Safety Act.

Under the law, the NHTSA can let automakers that build fewer than 10,000 cars a years get by without meeting all the required standards if it finds the exemption is "in the public interest."

NHTSA let the company go ahead for a year and build the replicas but that year is up Sept. 1 and there are still four standards that its version of the Model A can't specifically meet.

One has to do with the steering wheel. Under the rules it has to have "impact protection for the driver," something clearly unattainable with a Model A replica steering wheel. So the company is using Ford Fairmont steering wheel and control system and hopes that will satisfy the agency.

Side door strength and fuel system integrity are two other standards the Model A people believe they may meet -- but say testing would be too costly for their small company. The tests involve running the car at 30 miles per hour into a solid barrier; having something hit it from the rear, also at 30 miles per hour and finally getting smacked from the side at 20 miles per hour. After one of these crashes, the car is also to be rolled over to check damage to the roof.

NHTSA officials agree the testing is "quite expensive" and means ruining at least one or two cars. But they point out the Model A doesn't have to do the tests, only make a "good faith effort" to show standards have been met.

There is one standard, however, that the Model A maker says it cannot meet without destroying "the character of the vehicle and its sales market." It is the rule requiring head restraints, those bumps on the back of the front seats designed to prevent whiplash or other painful injuries when a car is struck from front or rear.

To put in such restraints, the Model A maker says, would require a major reconstruction and most importantly "severely limit the leg room in the rumble seat . . ."

In pleading for another year of exemption, the company noted that in producing about 2,000 cars it has lost about $300,000. But it added that it had done something else in the course of the year "in the public interest" that might balance off its inability to meet safety standards. Among its 290 employes were 133 who "are receiving training or were trained under federal and state" job programs.

To refuse the exemption would force the company to close down and end this federally financed training program.

It is the first time, according to one NHTSA official, that a company has raised participation in another government program as a reason for a waiver of safety rules. But he added he "thought it was a legitimate public interest argument."