Interpretation ID: nht90-2.88

TYPE: Interpretation-NHTSA

DATE: June 15, 1990

FROM: James W. Lawrence -- Manager, Compliance and Technical Legislation, Volvo GM Heavy Truck Corporation

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: Re Interpretation on Conformance of Aftermarket Parts

ATTACHMT: Attached to letter dated 4-9-90 from Stephen P. Wood to Mehdi Rowghani (A35; Std. 214; Part 541); Also attached to letter dated 3-13-91 from Paul Jackson Rice to James W. Lawrence (A37; Std. 214; VSA 108(a)(2)(A))

TEXT:

I recently became aware of an Administration interpretation (copy attached) to a parts distribution that states in part as follows:

"...there is no requirement that the replacement door restore the vehicle to a condition in which it continues to meet Standard No. 214."

In contrast, the Act section 108a(2)(A) prohibits rendering inoperative devices or elements of design installed in compliance to a Safety Standard. I interpret this provision of the Act to require the installation of parts meeting the same performance r equirements as OEM parts. A clarification would be most appreciated.