Interpretation ID: nht88-1.10

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 4, 1988

FROM: ROBERT J. KAUFMAN -- GINGOLD, KAUFMAN & CHAIKEN

TO: NHTSA

TITLE: GK&C FILE NO. 1012-271

ATTACHMT: MEMO DATED 2-18-88, FROM ERIKA Z. JONES, TO ROBERT J. KAUFMAN, TITLED: GK & C FILE # 1012-271

TEXT: This law firm represents a Volvo dealership in the State of Georgia, which dealership purchases certain accessory products for the aftersale market. Specifically, one of the products which my client acquires is an armrest to be installed in a Volvo 240 s eries automobile, which product is acquired from a company known as Auto Accessories, Inc., located at P. O. Box 10044, New Iberia, Louisiana 70562. Recently, my client has received a circular from Auto Accessories, Inc., relative to the installation pr ocedure for the "240 armrest", which procedure ostensibly was either approved, mandated or suggested by the Department of Transportation. A copy of the circular is enclosed for your review.

It would greatly be appreciated if you could

furnish to the undersigned a detailing of the specific installation procedures for the "240 armrest". Moreover, it would be appreciated if you would advise the undersigned as to whether these procedures are merely suggested or required.

Of additional concern is the question as to whether the installation procedure which the Department of Transportation has suggested satisfies the "inoperative" or "inaccessible" test as alluded to in the National Traffic and Motor Vehicle Act of 1966, Standard No. 208, Section S7.2 and Section 108(A) (2) (a).

Finally, if your office has any additional information relative to this specific accessory, to-wit: the "240 armrest", or anything related to its installation, operation or tests or studies pertaining to it, it would be most helpful if you could furni sh to the undersigned copies of all relevant data. Naturally, we would be more than happy to be invoiced for any costs incurred in the production of these documents.

Obviously, it is my client's firmest desire to provide the utmost in safety to its customers, and, consequently, my client is most desirous of insuring that the accessories which it installs and the method of installation are of the highest caliber an d any information that you could provide to facilitate that endeavor will be received most graciously. Thank you for your kind assistance and cooperation.

ENCLOSURES