Interpretation ID: nht72-6.6

DATE: 11/07/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Urban Economics Research Group

TITLE: FMVSR INTERPRETATION

TEXT: This is in further reply to your letter of August 31, 1972, to Mr. Bradford Crittenden, Regional Administrator, NHTSA, San Francisco, California, that has been referred to this office.

It appears from your letter that persons will not be able to ride in the device you plan to manufacture while the vehicle is in motion. If this is the case, the device would not be subject to the Federal Motor Vehicle Safety Standards at this time.

If this is not the case, however, we will need more information, including pictures or drawings, if possible, in order for us to accurately determine whether federal requirements are applicable.

A manufacturer of such a device would be considered a manufacturer of automotive equipment within the meaning of the National Traffic and Motor Vehicle Safety Act, copy enclosed. The device and mountings would be expected to be free of safety related defects.

If you have further questions, we will be pleased to answer them.