Interpretation ID: nht80-2.12

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Gas Alternatives Systems

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 1, 1980, letter asking what you must do to certify devices that you plan to import for sale in the United States. The devices to which you refer would convert an automobile's fuel system from gas to compressed natural gas or propane.

The National Highway Traffic Safety Administration issues safety standards and requires manufacturers of motor vehicles and equipment to certify that their vehicles or equipment comply with all applicable standards. To certify compliance to the standards, manufacturers must test or conduct some form of analysis of their vehicles or equipment. The Federal government does not get involved in the actual certification process. Once a manufacturer determines that its equipment or vehicles comply with the standards, it can then certify the vehicles or equipment without getting government approval.

With respect to the device that you propose to import, the agency has no safety standards applicable to this type of a device. Accordingly, as an importer of this equipment, you would have no certification responsibilities. However, the agency has a vehicle safety standard regulating fuel systems. If your device were designed to be installed in new motor vehicles, the manufacturer of those vehicles would be required to insure that your device would comply with the standard applicable to fuel systems. If your device would be installed on used vehicles, no manufacturer, dealer or repair business would be permitted to installed it if such installation would render inoperative the compliance of the vehicle with the safety standards.

To help clarify these general guidelines further, I am enclosing a copy of Part 567, Certification, which describes how to certify a vehicle in compliance with the safety standards. Further, I am enclosing a copy of our Safety Standard No. 301, Fuel System Integrity, which details the fuel system requirements for motor vehicles. Finally, we have prepared a short letter that gives information on the installation of alternate fuel systems in motor vehicles and that is enclosed for your information.

If we can be of further assistance, please contact us.

ENC.