ID: nht89-1.98

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: PAUL WALKER -- PRESIDENT SUNGUEST, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 02/17/89 FROM PAUL WALKER TO ERIKA Z. JONES -- NHTSA; OCC 3157

TEXT: Dear Mr. Walker:

Thank you for your letter regarding your company's efforts to export a product to Saudi Arabia. The product in question is identified in your letter as "remote-controlled electronic automobile window shades." Your letter indicates that your company's to tal production for the next two years will be for export only. It is my understanding that your company must provide the Saudi Arabian Standards Organization with a statement from this agency that we would "have no objection to the product in the U.S. m arket" before "large quantities" of the product can be shipped into Saudi Arabia. I am pleased to have this opportunity to respond to your request.

At the outset, I would like to make clear that the United States does not use a certification process similar to that used by the European countries, in which a manufacturer delivers its products to be certified to a governmental entity, and that entity tests the products to determine if they can be certified as complying with the applicable standards. Instead, in the United States, the individual manufacturer of the product is responsible for certifying that its products meet all applicable U.S. safe ty standards. After the manufacturer has made the necessary certifications, the product may be sold to the public without any "approvals" or "endorsements" from this agency.

In the case of your window shades, NHTSA has no standard that establishes requirements for window shades as items of motor vehicle equipment. Thus, your company is not required to make any certification of the window shades before offering them for sale . We do have two safety standards that might affect the installation of window shades in new vehicles. The first is Standard No. 205, Glazing Materials, which specifies performance requirements for glazing used in motor vehicles. These requirements in clude specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars). The second is Standard No. 302, Flammability of Interior Materials, which sets forth flammabili ty

resistance performance requirements for window shades installed in new vehicles. No manufacturer or dealer could legally install any window shades, including the shade developed by your company, in a new vehicle unless the manufacturer or dealer cer tifies that the vehicle with the window shade installed complies with Standards No. 205 and 302, as well as any other applicable standards.

To enforce the requirements in our laws and regulations, we conduct spot checks of motor vehicles and items of motor vehicle equipment after they have been certified and/or sold to the public or otherwise introduced into interstate commerce. For these s pot checks, we purchase the vehicles or item of equipment and test it according to the procedures specified in the applicable safety standard. If the product passes the tests, no further steps are taken. If the product fails the tests and is determined not to comply with the applicable standards or if it is determined that the product contains a defect related to motor vehicle safety, the manufacturer of the product is required to remedy the problem, by repairing or replacing the product at no cost to the purchaser. Since your product has not yet been sold in the United States, NHTSA has not made any spot checks or other evaluations of your product.

With that explanation, we will state that the window shades developed by Sunquest, Inc. could legally be sold to the public in the United States and could legally be installed on new vehicles to be sold to the public in the United States, if the vehicle manufacturer certifies that the vehicle with the window shades installed complies with all applicable safety standards.

I hope this information is helpful. If you have any further questions or need additional information, please contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

ID: 7763

Ms. Mindy Lang
Division Manager
Huntleigh Transportation Services Inc.
#12 Millpark Court
Maryland Heights, MO 63043

Dear Ms. Lang:

This responds to your letter of September 12, 1992, requesting information on regulations concerning bus conversions. Your company converts the interior of buses by installing such materials as carpets, wall coverings, and blinds. In particular you asked for information on regulations concerning the attachment of seats to vehicles and the material used for the construction of seats. I am pleased to have this opportunity to explain our law and regulations to you.

The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA has exercised its authority to establish one safety standard relevant to seating, Standard No. 207, Seating Systems, which establishes strength and other performance requirements for vehicle seats. However, this standard excludes passenger seats on buses from these performance requirements. There is one other safety standard that could be affected by the work your company performs. Standard No. 302, Flammability of Interior Materials, specifies burn resistance requirements for materials used in motor vehicles, including buses.

If your company converts previously certified buses, it could be considered an alterer under our regulations. Under 49 CFR Part 567, Certification, an alterer is defined as:

A person who alters a vehicle that has been previously certified ... other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ... before the first purchase of the vehicle in good faith for purposes other than resale ....

If considered an alterer, your company would be subject to the certification requirements of 49 CFR 567.7. These requirements include provisions that the alterer supplement the original manufacturer's certification label, which must remain on the vehicle, by affixing an additional label. The label must state that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards, including Standard No. 302. The label must also state the name of the alterer and the month and the year in which the alterations were completed.

Your company would not be subject to the certification requirements of 49 CFR 567.7 if the modifications involve only readily attachable components. However, the modifications would still be affected by section 108(a)(2)(A) of the Safety Act. That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard.

Any violation of this "render inoperative" prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation.

I hope you find this information helpful. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on manufacturers, and tells how to get copies of the relevant laws and regulations. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure ref:#207,#301 d:10/20/92

ID: nht92-3.14

DATE: October 20, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Mindy Lang -- Division Manager, Huntleigh Transportation Services, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 9/12/92 from Mindy Lang to Office of Chief Council, NHTSA (OCC-7763)

TEXT:

This responds to your letter of September 12, 1992, requesting information on regulations concerning bus conversions. Your company converts the interior of buses by installing such materials as carpets, wall coverings, and blinds. In particular you asked for information on regulations concerning the attachment of seats to vehicles and the material used for the construction of seats. I am pleased to have this opportunity to explain our law and regulations to you.

The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1181 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA has exercised its authority to establish one safety standard relevant to seating, Standard No. 207, Seating Systems, which establishes strength and other performance requirements for vehicle seats. However, this standard excludes passenger seats on buses from these performance requirements. There is one other safety standard that could be affected by the work your company performs. Standard No. 302, Flammability of Interior Materials, specifies burn resistance requirements for materials used in motor vehicles, including buses.

If your company converts previously certified buses, it could be considered an alterer under our regulations. Under 49 CFR Part 567, Certification, an alterer is defined as:

A person who alters a vehicle that has been previously certified ... other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ... before the first purchase of the vehicle in good faith for purposes other than resale ....

If considered an alterer, your company would be subject to the certification requirements of 49 CFR S567.7. These requirements include provisions that

the alterer supplement the original manufacturer's certification label, which must remain on the vehicle, by affixing an additional label. The label must state that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards, including Standard No. 302. The label must also state the name of the alterer and the month and the year in which the alterations were completed.

Your company would not be subject to the certification requirements of 49 CFR S567.7 if the modifications involve only readily attachable components. However, the modifications would still be affected by section 108(a)(2)(A) of the Safety Act. That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard.

Any violation of this "render inoperative" prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation.

I hope you find this information helpful. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on manufacturers, and tells how to get copies of the relevant laws and regulations. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: aiam3504

Dear Mr. Holsten: This responds to your November 25, 1981, letter asking whethe children's car seats must comply with the flammability requirements of Standard No. 302, *Flammability of Interior Materials*. The answer to your question is yes. Section S5.7 of Standard No. 213, *Child Restraint Systems*, specifically states that each material used in a child restraint system shall comply with the flammability requirements of Standard No. 302.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3505

Dear Dr. Holsten: This responds to your November 25, 1981, letter asking whethe children's car seats must comply with the flammability requirements of Standard No. 302, *Flammability of Interior Materials*. The answer to your question is yes. Section S5.7 of Standard No. 213, *Child Restraint Systems*, specifically states that each material used in a child restraint system shall comply with the flammability requirements of Standard NO. 302.; Sincerely, Frank Berndt, Chief Counsel

ID: GRAMMLT.ogm

The Honorable Phil Gramm
United States Senator
2323 Bryan Street, #1500
Dallas, Texas 75201

Dear Senator Gramm:

Thank you for your letter of June 21, 1996, on behalf of your constituent, Mr. Milton C. Beveridge. Mr. Beveridge apparently wishes to modify the rear seats of a 1996 Chrysler 15 passenger van to create better access for elderly passengers who, in order to reach seats in the rear of the van, must pass through the limited space between the edges of the seats and the rear wheel housing. In order to provide better access, Mr. Beveridge wishes to have these seats made narrower so that they would seat two passengers rather than three and create a wider opening between the seats and the wheel housing. However, Mr. Beveridge is unable to find a facility that will perform this work because of an existing state requirement that any work on the van, which was purchased through a state grant, be performed by a "certified" repair facility. In addition, in speaking with the dealer who sold the van and representatives of Chrysler, Mr. Beveridge has been told that the seats in the van cannot be modified without violating federal law.

As discussed below, there is no blanket Federal prohibition against modifying seats. However, Federal law does specify that dealers and repair businesses making such modifications must do so in a way that does not compromise the occupant protection provided by the vehicle manufacturer in accordance with Federal standards.

Some background information about our agency may be helpful. The National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motorvehicle equipment. Federal law prohibits the manufacture or sale of any new motor vehicle or new item of motor vehicle equipment which does not conform to all applicable Federal motor vehicle safety standards.

After the first retail sale, there is a limit on the modifications that can be made by certain businesses to vehicles. Manufacturers, distributors, dealers, and repair businesses may not "knowingly make inoperative" any device or element of design installed on or in a motor vehicle or equipment in compliance with an applicable safety standard.

Since the seats and their safety belts are devices or elements of design that were installed in your constituent's van in compliance with applicable standards, none of these businesses may modify the vehicle in such a manner that it no longer complies with a safety standard. Accordingly, such a business should examine the relevant Federal motor vehicle safety standards in these areas, e.g., Standards Nos. 207, Seating Systems, 208, Occupant Crash Protection, 209, Seat Belt Assemblies, 210, Seat Belt Assembly Anchorages, and 302, Flammability of Interior Materials, to determine how modifications can be made in a manner that does not adversely affect compliance.

The foregoing standards may be found in Sections 571.207, 571.208, 571.209, 571.210 and 571.302 of Volume 49 of the Code of Federal Regulations ,(49 CFR 571.207 et.seq.). We are providing Mr. Beveridge with copies of these standards under seperate cover.

As noted above, Mr. Beveridge's letter indicates that he is having difficulty finding a "certified" repair facility to modify his vehicle. NHTSA does not "certify" repair shops or approve modifications to privately owned vehicles. As Mr. Beveridge indicates that the requirement that any modification be performed by a "certified" facility is imposed by the state, I suggest that he contact an appropriate state government official for assistance in how to find such a facility.

I hope this information is helpful. Should you have any further questions or need additional information, feel free to contact me or Mr. Otto Matheke of the Office of Chief Counsel at (202) 366-5253.

Sincerely

John Womack

Acting Chief Counsel

Enclosure

Constituent's Correspondence

ref:208

d:9/20/96

ID: 8034

Mr. Daniel Cassese
28 Elva Road
N. Weymouth, MA 01291

Dear Mr. Cassese:

This responds to your letter of November 19, 1992. Your letter describes your invention called a "Head Rest Extension." You asked if this invention would comply with Federal Motor Vehicle Safety Standards Nos. 201, 202, and 208.

By way of background information, the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA has exercised its authority to establish four safety standards which could be relevant to a head rest extension: Standard No. 201, Occupant Protection in Interior Impact, Standard No. 202, Head Restraints, Standard No. 208, Occupant Crash Protection, and Standard No. 302, Flammability of Interior Materials.

These four standards apply only to new vehicles, not to items of individual equipment. If the head rest extension were installed before the vehicle's first purchase for purposes other than resale, the vehicle would have to be certified as complying with all applicable standards, including these four, with the head rest extension installed. However, as you have explained in a phone conversation with Mary Versailles of my staff, your product is intended to be an item of after-market equipment.

After a vehicle's first purchase for purposes other than resale; i.e., the first retail sale of the vehicle, the only provision in Federal law that affects a vehicle's continuing compliance with an applicable safety standard is set forth in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

Any violation of this "render inoperative" prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. Please note that the "render inoperative" prohibition does not require manufacturers, distributors, dealers, and repair businesses to certify that vehicles continue to comply with the safety standards after any aftermarket modifications are made. Instead, "render inoperative" prohibits those entities from performing aftermarket modifications that they know or should know will result in the vehicle no longer complying with the safety standards.

Please note also that the "render inoperative" prohibition does not apply to modifications vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your head rest extension in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, individual States have the authority to regulate modifications that individual vehicle owners may make to their own vehicles.

You should also note that a head rest extension would be considered "motor vehicle equipment" within the meaning of the Safety Act. Therefore, if it contained a defect (either in manufacture, design, or performance) that relates to motor vehicle safety, you would be required to conduct a recall campaign to notify owners and to remedy the defect free of charge.

I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on manufacturers, and tells how to get copies of the relevant laws and regulations.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure

ref:VSA#201#202#208#302 d.1/5/93

ID: nht95-1.10

TYPE: INTERPRETATION-NHTSA

DATE: January 5, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Donald Orlando -- Orlando World Industries

TITLE: NONE

ATTACHMT: Attached to 10/21/94 letter from Donald Orlando to Ed Glancy

TEXT: Dear Mr. Orlando:

This responds to your letter concerning whether your "Seat Belt Buddy" would be affected by any Federal Motor Vehicle Safety Standards issued by this agency. You describe the product as "a stuffed toy animal with a slit in the center of the animal where you insert the seat belt through and then into the automobile's buckle."

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. The agency does not approve, certify or endorse any vehicles or equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet all applicable standards. The following represents our opinion based on the facts provided in your letter.

There is currently no Federal motor vehicle safety standard that would apply to your product. We do have a standard (Standard 209, Seat belt assemblies) that sets forth requirements for new seat belt assemblies. We also have a standard (Standard No. 30 2, Flammability of Interior Materials) that sets forth flammability resistance requirements for the originally installed safety belts of the vehicle. However, since your product would not be part of a new seat belt assembly, these standards would not ap ply.

While no Federal motor vehicle safety standard applies to your product, your device is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. @@ 30118-30121 con cerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-r elated defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 49 U.S.C. section 30122, which prohibits them from installing the device if the installation "makes inoperative" compliance with any safety standard. I t appears unlikely from the nature of your product that it would be placed in vehicles by commercial businesses instead of consumers. However, if your product were to be installed by persons in those categories, they must ensure that its installation doe s not compromise the safety protection provided by the vehicle belt system. For example, they must ensure that the Seat Belt Buddy does not impair the function of the safety belt or belt retractor, or vitiate the compliance of the belts with Standard No . 302. The prohibition of section 30122 does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment.

Please note that the addition of any device to a vehicle's belt system raises possible safety concerns. Our safety standards require specific levels of performance for a vehicle's safety belt system. For example, Standard 208 has requirements that ensu re that a vehicle's lap and shoulder belts are installed to distribute the crash forces over the skeletal structure of the occupant. The safety standards also have requirements for belts to automatically lock and retract. We urge you to carefully evalu ate whether your product would in any way compromise the safety protection provided by the vehicle belt system, and whether instructions to the consumer are needed to advise about the proper use of the product. Among other things, you should evaluate wh ether children are likely to play with the "Seat Belt Buddy" in a manner that either introduces excessive slack in the shoulder belt, thereby reducing the protection provided by that belt in the event of a crash, or the inadvertent unlatching of the belt system. Finally, since the originally installed safety belts must meet the requirements of Standard No. 302, Flammability of Interior Materials, we encourage you not to degrade the flammability performance of safety belts.

I hope this information has been helpful. If you have any other questions, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992.

Sincerely,

ID: nht92-7.50

DATE: April 3, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Frederick Harris -- Frederick Harris Associates

TITLE: None

ATTACHMT: Attached to letter dated 2/5/92 from Frederick Harris to National Highway Traffic Safety Institute (OCC 6971)

TEXT:

This responds to your letter asking about Federal motor vehicle safety standards applicable to your product, which you described as a cloth device containing plastic items useful to a baby, for use in motor vehicles. You explained that your product would be placed in a motor vehicle adjacent to, but not touching, a child in a nearby child safety seat. In particular, you were concerned about flammability resistance standards applicable to your product. I am pleased to have this opportunity to explain our requirements to you. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Section 102(4) of the Safety Act defines, in relevant part, the term "motor vehicle equipment" as:

any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle ...

In determining whether an item of equipment is considered an accessory, NHTSA applies two criteria. The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine the expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an "accessory" and thus is subject to the provisions of the Safety Act.

Applying these criteria to the cloth device containing baby items, it appears that your product would be an accessory and thus an item of motor vehicle equipment under the Safety Act. Based on our understanding of your device, it appears that a substantial portion of its expected use will be during the operation of a motor vehicle. In a telephone conversation with Ms. Dee Fujita of my staff, you explained that your device is intended to be sold for use in motor vehicles. In addition, it appears that your product would typically be used by ordinary users of motor vehicles.

While it appears that your device would be considered an item of motor vehicle equipment, this agency has not issued any standards setting forth performance requirements for such a device. Obviously, your device could not be

determined to be in noncompliance with a safety standard if there is no applicable safety standard.

As for your concern about flammability resistance requirements, please be advised that our safety standard about this issue, Standard No. 302, Flammability of Interior Materials, (49 CFR S571.302, copy enclosed), would not apply to your device. That standard sets forth such requirements applicable to new motor vehicles and not to motor vehicle equipment.

You should be aware that, as a manufacturer of an aftermarket item of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that you or NHTSA determines that your product contains a safety related defect, you would be responsible for notifying purchasers of the defective equipment and for remedying the problem free of charge.

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

Attachments

Two NHTSA information sheets dated September, 1985, entitled Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment and Where to Obtain Motor Vehicle Safety Standards and Regulations. (Text of attachments omitted.)

ID: aiam0612

Dear Mr. Davis: This is in reply to your letter of February 10, 1972, requesting ou comments relative to the time span over which examination might be contemplated under Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; Any vehicle to which a motor vehicle safety standard is applicable i required to conform to the standard until the vehicle has been sold to a purchaser for a purpose other than resale (15 U.S.C. S1397). In the case of Standard No. 302, the standard becomes effective September 1, 1972, and any vehicle manufactured after that date must comply until after its sale to such a purchaser.; Yours truly, Richard B. Dyson, Assistant Chief Counsel