Interpretation ID: 2679y
1134 Ross Avenue
St. Paul, MN 55106
Dear Mrs. Anderson:
Thank you for your letter asking for an explanation of the legal requirements that would apply to a product you would like to market. Before discussing the substantive issues raised in your letter, I would like to respond to your request that NHTSA not publicly disclose the details of this product. We hereby grant this request. Your letter, which contains the details of this product will not be made available to the public. As Steve Kratzke of my staff explained to you in a telephone conversation on September 19, all of our interpretation letters are available to the public. Thus, this letter will be publicly available. However, I will not discuss any specific features of your product in this letter.
Your letter indicated that your proposed product would alter the alignment of the shoulder belt to increase comfort for the person wearing the shoulder belt. This agency has discussed the legal requirements that might apply to devices that realign the shoulder belt in a February 11, 1988 letter to Mr. Roderick Boutin. I have enclosed a copy of that letter for your information. You should also note that your proposed product would be considered "motor vehicle equipment," within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on such manufacturers, and tells how to get copies of the relevant laws and regulations.
I hope this information is helpful. If you need any further information or have some questions, please feel free to contact Mr. Kratzke at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosures ref:208 d:l0/l/90