Interpretation ID: nht68-1.42

DATE: 05/28/68

FROM: AUTHOR UNAVAILABLE; J. R. O'Gorman; NHTSA

TO: Minnesota Automotive, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 1, 1968, to the Motor Vehicle Safety Performance Service, concerning compliance with the Federal Motor Vehicle Safety Standard No. 105.

Basically, when a car dealer modifies a conforming vehicle, he then assumes responsibility for the vehicle's compliance to all applicable standards if that vehicle is distributed to a purchaser for purposes other than resale. Specifically, if a car dealer installs the Model 7900 Driver Training Brake on a conforming vehicle that he sells, than compliance to the Federal Motor Vehicle Safety Standard No. 105, as well as other applicable standards, is required. In the case where the dealer owns and loans the vehicle with the installed Model 7900, we would hope that he would again comply.

The enclosed literature may be of additional assistance to you in response to your inquiry.