Interpretation ID: aiam2708
Route #1
Box 416
Cleveland
NC 27013;
Dear Mrs. Foster: Your recent letter to President Carter concerning the installation of bench seat in a cargo van was forwarded to the National Highway Traffic Safety Administration for reply. You were apparently told by your local Ford dealer that Federal law prohibits the installation of a seat in the cargo area of a van vehicle.; The Ford dealer's representation to you was incorrect. There is n Federal law that precludes installation of a seat such as your letter describes, although, depending on the time and manner of the installation, the seat might be subject to Federal safety standards.; If the vehicle manufacturer (Ford) or your dealer installs the sea prior to the time you take possession of the vehicle, either will have to certify that the vehicle, including the seat, is in compliance with all applicable safety standards, as provided in the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1381 *et seq*.). Specifically, the installation of the seat would require compliance with Safety Standard No. 207, *Seating Systems*, Safety Standard No. 208, *Occupant Crash Protection*, and Safety Standard No. 210, *Seat Belt Anchorages*. If done by your dealer, he would be required to attach a label or tag to the vehicle certifying that, as altered, the vehicle was in compliance with all safety standards, including the three just mentioned (49 CFR 567.7).; If you first take possession of the vehicle, you or your dealer ma then install an additional seat without certifying compliance with Federal safety standards (15 U.S.C 1397). Your dealer would, however, be subject to section 108(a)(2)(A) of the Vehicle Safety Act, which 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 in compliance with an applicable Federal motor vehicle safety standard. This means that the dealer would not be permitted to destroy the vehicle's conformity to any safety standard by his installation of the additional seat. We do strongly recommend that, for the safety of your child, you assure the seat and safety belts conform to the minimum performance requirements of our safety standards.; Perhaps it is the policy of Ford Motor Company and its dealers not t install additional seats in cargo vans because of the responsibilities mentioned above. The policy is not, however, a Federal law. I suggest you show this letter to your local dealer.; Sincerely, Joseph J. Levin, Jr., Chief Counsel