Interpretation ID: aiam3776
901 North Beach Road
Bow
WA 98232;
Dear Mr. Duvall: We have received your letter of October 27, 1983, informing us of you plans to provide a front-end replacement kit for 1971-77 Chevrolet Vegas. You have asked whether incorporating a 1973 bumper mounting hardware will meet safety regulations. You have also asked for a copy of front lighting requirements, and for information on how you may certify your kit for national distribution.; As you have not provided us with a description of all equipment item in the kit, I can offer only general guidance. There are very few requirements for fabricators of kits intended to modify used vehicles. The Federal motor vehicle safety standards are of two types: those that apply to vehicle systems, and those that apply to individual equipment items. The so-called 'bumper standard' is an example of a systems standard. Standard No. 215, *Exterior Protection*, which applied to passenger cars manufactured between September 1, 1972, and September 1, 1978, did not directly apply to the bumper itself but established a level of damage resistance to be met by the vehicle in low-speed frontal impacts.; On the other hand, the vehicle lighting standard applies to bot lighting systems and replacement lighting equipment. The primary statutory obligation of a kit supplier lies in this area--to determine if any item of equipment in the kit is covered by an equipment standard, and then to insure that the item meets the standard. For example, Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, required 1971-77 Chevrolet Vegas to be equipped with sealed beam headlamps. Were unsealed European headlamps to be furnished as part of the kit, that sale would be in violation of the National Traffic and Motor Vehicle Safety Act. Other equipment standards cover brake hoses, tires, brake fluids, glazing, and seat belts. Usually the manufacturer of equipment items covered by standards will certify compliance with Federal requirements by marking them with the symbol 'DOT'. In that event, no recertification by the kit supplier is required.; A further important obligation of a kit supplier is to insure tha safety-related defects are absent, or do not develop, in any motor vehicle equipment that he fabricates. If such occur, he is required to notify purchasers and remedy the defects.; There is also a provision of the Safety Act that has some relevance t your operation. Although a vehicle owner may modify his car in any manner he chooses, a restriction is established on modifications by others. That restriction is that 'no device or element of design' added to a vehicle enabling it to comply with a safety standard shall be 'rendered inoperative in whole or in part.' Thus, were a repair shop to remove the Vega front end and replace it with yours, the shop must insure that the Vega upon reassembly remains in compliance with the standards that originally applied to it. Although the kit supplier is not required under the Safety Act to insure that the Vega continues to comply with Standard No. 215, such insurance obviously assists the modifier in meeting its Federal responsibilities, and your incorporation of a 1973 bumper and attachments is helpful. The modified Vega must also continue to meet Federal lighting requirements, such as being equipped with front side marker lamps, and having no cover or other object over the headlamps when they are in use.; To assist you, I enclose copies of Standards Nos. 108 and 215 as the were in effect on October 1, 1977, the requirements were substantially the same for the other years in which you are interested. There is no charge and I am returning your check. If you have further questions, we shall be happy to answer them.; Sincerely, Frank Berndt, Chief Counsel