Interpretation ID: aiam2606
2729 Vandenberg Avenue
Omaha
NE 68123;
Dear Mr. Flesch: This responds to your letter to the President dated February 8, 1977 which has been forwarded to our office by the Department of Justice. You are concerned whether there is a Federal law that prohibits the replacement of a single part of a seat belt assembly, as opposed to replacement of the entire assembly.; The National Highway Traffic Safety Administration (NHTSA) issue safety standards and regulations that govern the manufacture of motor vehicles and motor vehicle equipment. Safety Standard No. 209, *Seat Belt Assemblies*, specifies requirements for seat belt assemblies to be used both as original equipment in passenger cars and as aftermarket replacement equipment. Vehicle manufacturers must certify that their vehicles are in compliance with all applicable safety standards, including Standard No. 209. There is no requirement in Standard No. 209, however, that would preclude the replacement or repair of a broken component in a seat belt assembly.; Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safet Act, as amended (15 U.S.C. 1381, *et*. *seq*.), provides that no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Therefore, none of the persons mentioned could replace or repair a component of a seat belt assembly if that action would destroy the compliance of the assembly with Standard No. 209. Violation of this section of the Safety Act could result in the imposition of civil penalties up to $1,000.; Perhaps it is General Motors' policy not to replace or repair component of a seat belt assembly because of the possibility that the assembly might, thereby, be 'rendered inoperative.' From the point of view of General Motors, replacement of the entire assembly with a new, certified, assembly might be a safer practice. General Motors is certainly entitled to operate under such a policy. The policy is not, however, a Federal law.; Sincerely, Joseph J Levin, Jr., Chief Counsel