Interpretation ID: nht67-1.19

DATE: 12/22/67

FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA

TO: McIntosh Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of November 3, 1967, to Mr. Lowell K. Bridwell, requesting clarification on certain aspects of the Motor Vehicle Safety Act.

In answer to your specific questions, please be advised that the supplier of a component of a motor vehicle is a manufacturer within the meaning of the Motor Vehicle Safety Act. However, he is not obligated to certify that the item of motor vehicle equipment he manufactures complies with the standard unless he is supplying that item to a distributor or dealer, and then only if there is an applicable Federal Standard.

As regards identification of parts, there is no specific requirement under the Act.

With reference to the entire matter of keeping of records under Section 112(c), this Bureau has under study an appropriate program based on evaluation of certification experience during the next few months that will load to specific regulations. It is contemplated that these regulations will have an effective date of January 1, 1969.

If there is any other information you would like, I hope you will let me know.