Interpretation ID: aiam3824
Manager
Regulatory Affairs
Volvo of America Corporation
Rockleigh
NJ 07647;
Dear Mr. Shapiro: This is in response to your letter of March 23, 1984, petitioning th Administrator for a temporary exemption from Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*, to allow use of the Volvo Child Safety Seat in 2500 of Volvo's 240/260 series vehicles.; Section 123 of the National Traffic and Motor Vehicle Safety Ac provides authority to exempt only motor vehicles from compliance with any applicable motor vehicle safety standard. This authority does not extend to individual items of motor vehicle equipment. Inasmuch as Standard No. 213 specifies requirements for child seating systems for use in motor vehicles but does not require their installation in them as original equipment, it is considered an equipment standard, rather than a vehicle standard. This means that the agency has no authority to grant your petition for exemption. If you wish to pursue this matter further, you may submit a petition for rulemaking pursuant to 49 CFR Part 552 to amend Standard No. 213 in a manner that would allow the Volvo seat.; Sincerely, Frank Berndt, Chief Counsel