Interpretation ID: aiam0815
Safety Products
Inc.
331 East Brooks Road
Suite 11
Memphis
TN 38109;
Dear Mr. Farrelly: This is in reply to your letter of July 17, 1972, in which you as whether a person who installs on new vehicles a device you manufacture called the Safti-Stabilizer is required to recertify the vehicle.; A person will be required to recertify a new, completed vehicle if h modifies it is such a manner that he becomes a 'manufacturer' under the National Traffic and Motor Vehicle Safety Act. A person will be considered a manufacturer if the modifications he performs produce significant changes in the vehicle's configuration or purpose. while this determination is generally made on a case by case basis, examples of modifications which the NHTSA has considered to be 'manufacturing' include the addition of new axles, or the changing of a completed truck van into a motor home.; The NHTSA has taken the position, in close cases, that it will accept good-faith determination of a person modifying new vehicles as to whether the modification is of such a nature so as to make that person a manufacturer. Based on the information you have provided to us, it appears that the installation of the Safti-Stabilizer does not significantly change the vehicle's configuration or purpose. Consequently, we would accept a determination that the installation of the Safti-Stabilizer does not constitute remanufacturing, and a person who installs the device on new vehicles need not recertify them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel