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Interpretation ID: aiam3140

Honorable John D. Dingell, House of Representatives, Washington, DC 20515; Honorable John D. Dingell
House of Representatives
Washington
DC 20515;

Dear Mr. Dingell: This responds to your recent letter on behalf of your constituent, Mr Donald Edwards. Mr. Edwards asks whether the passenger seat in a 1979 Dodge van is required under Federal law to be equipped with a safety belt.; Your earlier answer to Mr. Edwards was correct. Federal Motor Vehicl Safety Standards require light trucks (including vans) to be equipped with safety belts for each designated seating position. The passenger seat in Mr. Edwards' van would qualify as a designated seating position and would be required to have a safety belt.; Under the Federal certification regulations for motor vehicles, an person who alters a vehicle prior to its first purchase for purposes other than resale is required to place an additional label on the vehicle certifying that, as altered, the vehicle continues to be in compliance with all applicable safety standards (49 CFR 567.7). This provision would apply to the dealer who altered Mr. Edwards' vehicle by adding the passenger seat. The label would certify that the vehicle was still in compliance with all standards, including the safety belt requirements. Since the dealer did not install a safety belt, he probably did not place an alterer's label on the vehicle and he would, therefore, be in violation of the certification regulation. If this is the case, the agency has authority to require the dealer to remedy the noncompliance by installing safety belts on the van. Additionally, the dealer could be liable for civil penalties up to $1,000 for failure to comply with the Federal safety standards and regulations.; If Mr. Edwards has any problems in obtaining the required safety belt after receiving this information, please have him contact our Office of Enforcement at 400 Seventh Street, S.W., Washington, D.C. (202/426-9700).; Sincerely, Joan Claybrook