Interpretation ID: aiam4258
859 South Main
Plymouth
MI 48170;
Dear Mr. Tackett: This is to follow-up on your phone conversation of December 1, 1986 with Stephen Oesch of my staff concerning how Standard No. 301, *Fuel System Integrity*, affects the installation of trailer hitches on cars. I hope the following discussion answers your questions.; Standard No. 301 sets performance requirements to reduce fuel syste spillage in a crash. If a trailer hitch is installed on a *new* car prior to the car being first sold to a consumer, the person installing the trailer hitch would be considered a vehicle alterer under our certification regulation (49 CFR Part 567), a copy of which is enclosed. Under Part 567.7, a vehicle alterer is required to certify that the vehicle, as altered, still conforms with all applicable safety standards.; The installation of a trailer hitch on a used car would be affected b section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) provides that:; >>>No manufacturer, distributor, dealer or motor vehicle repai 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 . . . .<<<; Thus, in installing trailer hitches on a used car, a commercia business must ensure that it has not knowingly compromised the integrity of the fuel system.; In addition, a manufacturer of motor vehicle equipment, such as trailer hitch, is subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. I have enclosed an information sheet which briefly describes how our defect regulations affect equipment manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel