Interpretation ID: 77-4.6

TYPE: INTERPRETATION-NHTSA

DATE: 09/28/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Cantey; Hanger; Gooch; Munn & Collins

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your August 9, 1977, letter asking whether an alterer's responsibility for ensuring the compliance of a vehicle with Federal safety standards, as required in Part 567, Certification, extends only to those aspects of performance that could have been affected by the alteration or whether it extends to the compliance of the entire vehicle with all Federal standards.

The intent of the alteration regulation is to make vehicle alterers responsible for the continued compliance of the vehicles they modify. Therefore, an alterer would be held responsible for any noncompliance of a vehicle caused by his alterations. The National Highway Traffic Safety Administration would not hold the alterer liable for noncompliances in a vehicle that were the responsibility of the original vehicle manufacturer and not affected by the alterer's conduct.