Interpretation ID: aiam2046
Owner
The Hardy Heater Company
9609 Dixie Highway
Louisville
KY 40272;
Dear Mr. Hardy: This is in response to your letter of July 30, 1975, in which yo inquire as to any rules and regulations to which you may be subject with respect to your pre-heater defroster. Your letter was referred to this office by the Environmental Protection Agency.; We assume, from the material submitted with your letter, that you pre-heater is sold for installation in used cars and supplements the vehicle's existing defrosting system. If our assumption is incorrect, please advise us. If your pre-heater is installed in a motor vehicle prior to its first purchase or if it replaces an existing defrosting system, you will be subject to regulations in addition to those mentioned in this letter.; The National Traffic and Motor Vehicle Safety Act provides that manufacturer, dealer, distributor, or repair shop may not render inoperative any safety device or design in a motor vehicle after its first purchase by the owner. this means that the installation of the pre-heater must not take the vehicle out of compliance with an applicable Federal Motor Vehicle Safety Standard. The standard with which you will likely be most concerned is Standard No. 103, *Windshield Defrosting and Defogging Systems* (copy enclosed).; In addition, if the fuel used in your pre-heater has a boiling poin greater than 32 degrees Fahrenheit, you must ensure that the pre-heater fuel system complies with Standard No. 301, *Fuel System Integrity* (copy enclosed).; Thank you for your interest in motor vehicle safety. Yours truly, Richard B. Dyson, Assistant Chief Counsel