Interpretation ID: aiam0914
Vice President & General Manager
Pride Products Co.
Inc.
101 East Alameda Avenue
Burbank
CA 91502;
Dear Mr. Dougherty: This is in reply to your letter of October 23, 1972, requestin information on the use of sample testing for determining conformity to Motor Vehicle Safety Standard No. 213. You ask if there are sampling provisions to which manufacturers should currently be adhering.; There is no specified sampling provision for manufacturers to follow i testing their products for conformity to Standard No. 213. The National Traffic and Motor Vehicle Safety Act requires each item of motor vehicle equipment (for example, each child seat) to conform to the applicable safety standard in effect on its date of manufacture. It is the manufacturer's responsibility to decide what type of testing program is necessary to be reasonably certain that each item complies. The extent of his sampling should depend on such factors as the margin by which typical samples pass the performance requirements, the amount of variation in production that is present, and the degree to which substandard items can be detected by non-destructive techniques.; Yours truly, Richard B. Dyson, Assistant Chief Counsel