Interpretation ID: 1983-1.22

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 4, 1983

FROM: HOUTAN MOSTAGHIM -- VICE PRESIDENT, PAN UNITED

TO: CHIEF COUNSEL -- NHTSA

TITLE: DOG CLIP.

ATTACHMT: MEMO DATED 3-21-83, FROM FRANK BERNDT, FROM HOUTAN MOSTAGHIM, NOA-30

TEXT: The purpose of this letter is to request official legal interpretation on a piece of safety device which, this company is currently intending to import and distribute in the territories of the United States.

This device refers to a so called "complimentory buckle component" of a seat belt, which is engaged and secured in a seat buckle component.

This device is designed to be attached and secured to the collar or homes of a pet in any vehicle with seat belt buckle component, in order to protect the driver from the pet's sudden and gross moves inside the vehicle.

For further clarification and explanation of this device, I am enclosing a copy of respective patent document for your kind review. This document is accompanied with a picture of the device in actual size, plus some other informative material and pictures.

What we need to find out are: 1-) Does this device apply to any of the National Traffic and Motor Vehicle Safety regulations? 2-) Do we need to obtain any kind of import permit from your organization to proceed with the importation of the device? 3-) Based on the regulations, does the device require any testing and licensing prior to actual commencement of importation? 4-) What types product liabilities should our company entertain, as the sole importer and distributor of this device? 5-) Can these liabilities be covered through appropriate insurance coverages. And if so, please kindly, supply us with a list of insurance companies that are currently involved in such underwritings. After the review of the material, you would realize that, this device is primarily designed to increase safety for the driver and other passengers, rather than the pet's. Therefore, we believe the prompt promotion and marketing of this device in the U.S., would directly contribute to relative improvement in highway and traffic safety concerns of your respected organization.

We would strongly entertain your suggestions, comments and advise on this matter. I am looking forward to your kind response, mean while I remain. ENCLS: AS STATED IN TEXT