Interpretation ID: 7246-3
28025 N. Sarabande Lane #1216
Canyon Country, CA 91351
Dear Mr. Balzak:
This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact. I apologize for the delay in our response. You stated that you have received a copy of this standard and would like clarification of two issues. Your questions are addressed below.
Your first question asked whether Standard No. 201 applied to passenger cars manufactured between January 1, 1968 and September 1, 1981. The answer to this question is yes; the standard applied to all passenger cars manufactured on or after January 1, 1968.
Your second question asked whether Standard No. 201 applies to instrument panels manufactured for replacement of damaged units. The answer to this question is that, by its own terms, Standard No. 201 applies only to new motor vehicles. This means that the standard applies to original equipment components, including instrument panels, but not to replacements for those components.
However, you should be aware of an important provision in Federal law. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that "(n)o manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . ." This provision applies to both new and used vehicles.
You specifically asked about the replacement of damaged instrument panels. I note that the Safety Act does not require a manufacturer, distributor, dealer or repair business to return a vehicle to compliance with a standard if a device or element of design has been "rendered inoperative" by another agent, such as a crash.
The prohibition of section 108(a)(2)(A) does not apply to individual owners who alter their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to tamper with the safety equipment installed on their vehicles.
I hope this information is helpful. If you have further questions, please feel free to contact Edward Glancy of my staff at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:201#VSA d:6/11/92