Interpretation ID: 86-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/13/86

FROM: JOSEPH A. GIAMPAPA

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 09/05/86 EST, TO JOSEPH A GIAMPAPA FROM ERIKA Z. JONES; REDBOOK A29; VSA 108

TEXT: Dear Ms. Jones:

My telephone inquiry to the Office of the General Counsel (Joanne Petrie, Esq.) was referred to Steven Ash, Esq., of your staff. The inquiry concerned whether or not a product one of my clients intends to manufacture might be subject to federal regulation. The subject device is an Auto Body Gauge for use by auto body specialists when performing repairs, and is not equipment actually used inside a vehicle. A copy of the patent covering this item is enclosed herewith for explanatory purposes.

I hereby request a formal opinion as to whether or not said device is subject to NHTSA regulations. I would also appreciate your passing on information about any other regulations you might know of which such a device might be subject to.

Meanwhile, let me thank you, in advance, for your time and careful attention to this matter. If I can be of further assistance in this inquiry, please do not hesitate to contact me.

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