Interpretation ID: aiam1802
Minnesota Automotive
Inc.
Box 2074
North Mankato
MN 56001;
Dear Mr. Cords: This is in reply to your letter of January 6, 1975, requesting a opinion on whether a person who installs a Mico Brake Lock device on a new vehicle before its sale to the first purchaser is required to affix an alterer label in accordance with 49 CFR SS 567.7 and 568.8. You state that you believe the device, which serves as a hydraulic parking brake, is readily attachable because it can be installed in a minimum amount of time and does not in any way alter the operation of the vehicle's original brake system.; The NHTSA will generally abide by a good faith determination on th part of a manufacturer that a device is readily attachable. Such a decision should be based primarily on the intricacy of the installation of the device. Simple tools, a relatively short installation time, and the ability to install the device without extensively modifying the vehicle would all be factors pointing to a decision that a component is readily attachable. You should note that section 567.7 of the Certification regulations also requires an alterer label when the installation of a component invalidates a vehicle's existing weight ratings, whether or not the component is readily attachable. On the basis of your letter, however, it appears to us that this would not occur as a result of installation of the Mico Brake Lock device.; If your device meets these criteria, no additional labeling will b required.; Yours truly, James C. Schultz, Acting Chief Counsel