Interpretation ID: nht76-3.8

DATE: 08/30/76

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: Interpretations File

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: TELEPHONE CALL FROM MR. DAVE HUNT, NADA

On August 26, 1976, I spoke with Mr. Dave Hunt of the National Automobile Dealers Association (821-7030). He referred to a letter sent by General Motors Corporation to some of its dealers, concerning the relation between dealer installations of trailer hitches and Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity. Because neither of us had actually seen the letter, we discussed that relationship in general terms. I explained that the installation of a trailer hitch on a used vehcle would be subject to the "knowingly render inoperative" provision -- Section 108(a)(2)(A) -- of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, and referred to Mr. Hunt to our May 18, 1976, letter on this subject to Mr. Larry Henneberger. I explained further that the most relevant portion of that statute concerning the installation of a trailer hitch on a vehicle before its first purchase in good faith for purposes other than resale would be Section 108(a)(1)(A).