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Interpretation ID: 2508y

Mr. Michael S. Kmiecik
5601 Western Avenue
Omaha, Nebraska 68132

Dear Mr. Kmiecik:

This responds to your letter with respect to vehicle modification kits you wish to purchase and use in the conversion of used Datsun cars. You asked about the Part 58l Bumper Standard and Safety Standard No. 2l5 with respect to using Datsuns produced before September l, l978. You asked whether the kit would meet the requirements of Safety Standard No. 2l5. I regret the delay in responding. (I note that you sent a separate letter asking about the safety standards that apply to l974-78 convertibles, and whether the conversion kit meets those standards. I am responding to that letter separately).

We appreciate your efforts to meet the requirements of the National Traffic and Motor Vehicle Safety Act. A provision of the Act requires, in essence, that vehicle alterations by a motor vehicle manufacturer, distributor, dealer or repair business must not render wholly or partially inoperative any device or element of design installed on that vehicle in accordance with a Federal motor vehicle safety standard. This means that a vehicle at the end of its conversion process must continue to meet the standards that applied at the time that it was first manufactured.

As you may know, the Part 58l Bumper Standard became applicable to passenger cars manufactured on or after September l, l978. It replaced Safety Standard No. 2l5, Exterior Protection, which applied to passenger cars manufactured from September l, l972 to August 30, l978.

In converting a car to which Standard No. 2l5 originally applied, care must be taken to ensure that the changes do not affect the ability to conform to the applicable performance requirements of that standard (copy enclosed). We regret that we are unable to advise you of the effect that any specific modifications would have on the performance of the vehicle as converted. The manufacturer of the kit may be able to provide information on this subject. You also requested a copy of Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment. I have enclosed a copy of that standard revised as of October l, l989. I have also enclosed an information sheet which provides information for new manufacturers, and includes information concerning how to obtain copies of safety standards.

I hope this information is helpful.


Stephen P. Wood Acting Chief Counsel