Interpretation ID: nht88-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 05/08/88

FROM: MARTIN M. GINSBURG

TO: ERIKA JONES -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/27/89 FROM STEPHEN P. WOOD -- NHTSA TO MARTIN M. GINSBURG -- PROLINE DESIGNS; REDBOOK A33; STANDARD 126; STANDARD 302 LETTER DATED 11/24/88 FROM MARTIN M. GINSBURG TO ERIKA Z. JONES -- NHTSA

TEXT: After speaking to Mr. George Shifflett and Mr John Messera concerning Motor Vehicle Safety Standard No. 302, they recommended that I ask you for a legal interpretation indicating that I do not need to comply with this standard.

My product consists of a window covering, also known as a curtain, which is made out of various fabric materials. This product is to be sold as an accessory for pick-up truck covers, also known as a shell or cap. This shell or cap is an after-market product. It is placed directly over the empty bed of the truck. There are no seats in the bed area or in the cover. Also this cover is segregated from the cab area.

I would appreciate a legal interpretation concerning my need to comply with the 302 standard.

Thank you