Interpretation ID: nht91-5.14

DATE: August 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Charles Saunders-White

TITLE: None

ATTACHMT: Attached to letter dated 7-8-91 from Charles Saunders-White to Steve Kratzke

TEXT:

This is in response to your letter asking whether any Federal Motor Vehicle Safety Standards were in effect in 1929, and from 1920-1934. You stated that you are building a vehicle, which the state of Wisconsin will title a "reconstructed vehicle", using the frame and body from a 1929 roadster. You indicated that the vehicle must conform to all 1929 state and Federal laws and asked whether, in 1929, any Federal standards required motor vehicles to be equipped with

(1) fenders; (2) bumpers; (3) hoods; (4) doors, or (5) windshield wipers (power or manual).

You also asked whether any Federal standards, in effect from 1920-1934, required motor vehicles to be equipped with these items.

To answer your question, there were no Federal Motor Vehicle Safety Standards in effect prior to the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1381 et seq., which was signed into law on September 9, 1966. This Act authorizes the National Highway Traffic Safety Administration to issue safety standards for motor vehicles and motor vehicle equipment. The initial group of Federal Motor Vehicle Safety Standards issued under the authority granted by the Safety Act took effect on January 1, 1968, except for Standard No. 209, Seat belt assemblies, which took effect on March 1, 1967. Thus, no Federal standards were in effect in 1929, nor between 1920 and 1934, that required vehicles to be equipped with the items of motor vehicle equipment listed above.