Interpretation ID: aiam1751
Safety Products
Inc.
2974 Vantage Drive
Memphis
TN 38131;
Dear Mr. Farrelly: This is in reply to your letter of December 23, 1974, asking whether person who installs a 'Steering Stabilizer' manufactured by Safety Products, Inc., is required to recertify the vehicle in which it is installed. You enclose a copy of a letter from me dated August 24, 1972, in which I stated that we would accept a determination that the installation of a 'Safti-Stabilizer' (the previous name of the Steering Stabilizer) did not constitute remanufacturing, and that a person who installed such a device need not recertify the vehicle on which it is installed.; Since my earlier letter, the NHTSA has issued regulations covering th alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. These regulations (49 CFR SS 567.7, 568.8, copy enclosed) supersede opinions such as the one we provided you, which was based solely on the more general provisions of the National Traffic and Motor Vehicle Safety Act and the certification regulations in effect at that time. Under the new regulations, which were effective February 1, 1974, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than 'readily attachable' components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.; From the description of your device, and the enclosed literature, i appears to require no special expertise or tools to install, and is thus probably readily-attachable. It would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that an alterer label is not required when a 'Steering Stabilizer' is installed on a completed vehicle before its sale for purposes other than resale.; Yours truly, Richard B. Dyson, Acting Chief Counsel