Interpretation ID: 86-5.14

TYPE: INTERPRETATION-NHTSA

DATE: 09/05/86 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: JOSEPH A. GIAMPAPA

TITLE: NONE

ATTACHMT: LETTER DATED 02/13/86, TO ERIKA Z JONES, FROM JOSEPH A GIAMPAPA, REGULATIONS, OCC-0202

TEXT: Dear Mr. Giampapa:

This responds to your letter dated February 13, 1986, regarding an auto body gauge which a client intends to manufacture. The accompanying material describes this device as "a gauge for aligning opposite points within opposite surfaces of a normally symmetric body." It could be used to align a vehicle body following damage in an accident or collision. You ask what Federal requirements are applicable to an auto body gauge. I regret the delay in responding to your letter.

This agency administers the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et seq.). Under section 103 of the Act, NHTSA has issued Federal motor vehicle safety standards which are applicable to new motor vehicles and their equipment. The auto body gauge described in your letter would apparently be used by commercial automobile repair businesses when repairing and realigning damaged car bodies. In previous interpretations, NHTSA has said that items, such as wheel balancing machines, are "repair shop" equipment and not "motor vehicle" equipment. The reason is that, although their only use is with a motor vehicle, they are not intended to be used principally by ordinary users of motor vehicle equipment. Thus, we would not consider your client's product an item of motor vehicle equipment.

I hope this information is helpful to you.

Sincerely