Interpretation ID: aiam1978
Esq.
Richards
Watson
Dreyfuss & Gershon
615 South Flower Street
Los Angeles
CA 90017;
Dear Mr. Brown: This is in response to your letter of May 19, 1975, in which yo request an interpretation that roof vent covers in recreational vehicles are excluded from the coverage of Motor Vehicle Safety Standard No. 205. Further, you ask our interpretation of the extent to which States may procedurally regulate the conformity of motor vehicles and motor vehicle equipment with Federal safety standards.; We have reviewed the extensive brief you submitted in relation to th applicability of Standard No. 205 to recreational vehicle roof vent covers manufactured by injection molding, and have determined that roof vent covers fall within the purview of the Standard. Nevertheless, we concur in your view that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures found in USAS Z26.1. Consequently, we intend to issue in the near future proposed rulemaking which would establish a surrogate testing procedure for this type of roof vent cover. Until this new procedure is adopted, the NHTSA intends to take no action against manufacturers who do not certify that their injection molded roof vent covers meet the requirements of Standard No. 205 which incorporate the requirements of USAS Z26.1.; With respect to State action concerning the conformity of moto vehicles and equipment to motor vehicle safety standards, we are currently reviewing our position in light of a suit brought last month against the State of Pennsylvania. We shall advise you when a conclusion has been reached.; Sincerely, James C. Schultz, Chief Counsel