Interpretation ID: nht92-4.11

DATE: September 11, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Arye Addady -- Maaco

TITLE: None

ATTACHMT: Attached to letter dated 7/22/92 from Arye Addady to U.S. Dept. of Transportation, NHTSA (OCC-7582)

TEXT:

This responds to your letter of July 22, 1992, concerning an invention that you are developing. You stated that your idea would involve installation of a device in the hydraulic brake system of a vehicle and asked whether permission is required from our agency. I am pleased to have this opportunity to explain our law and regulations for you.

The National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards for new motor vehicles and new motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards. Manufacturers are not required to seek permission from NHTSA, and this agency does not provide approvals of motor vehicles or motor vehicle equipment. Under the Safety Act, the manufacturer is responsible for certifying that its motor vehicles or equipment meet applicable standards.

I am enclosing a pamphlet which provides information for new manufacturers of motor vehicles and motor vehicle equipment. I am also enclosing copies of a January 4, 1985, letter to Deco International Corporation, and a January 5, 1982, letter to Cariben, Inc., which discussed Federal requirements applicable to certain aftermarket devices that were installed in the braking systems of vehicles.

I hope this information is been helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992.