Interpretation ID: nht88-4.19

TYPE: INTERPRETATION-NHTSA

DATE: 11/28/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL

TO: ROBERT L. RIPLEY -- PRESIDENT KNAACK MANUFACTURING CO.

TITLE: NONE

ATTACHMT: LETTER DATED 08/11/88 TO ERIKA Z JONES FROM ROBERT L. RIPLEY OCC -- 2406

TEXT: Dear Mr. Ripley:

This is a response to your letter asking this agency to review three product catalogs you submitted with your letter, and tell you whether your company is required to furnish information pursuant to 49 CFR Part 566, Manufacturer Identification. Based on the information you supplied with your letter, your company is required to file information under Part 566 for the warning devices shown in one of the catalogs, but not for any of the other items shown in the three catalogs.

As specified in the Application section of Part 566 (@ 566.3), Part 566 applies to (1) all manufacturers of motor vehicles and (2) manufacturers of motor vehicle equipment, other than tires, to which a safety standard applies. The only item advertised i n the three catalogs that is motor vehicle equipment to which a safety standard applies is the "Safety Reflector Kit" shown on page 6 of the catalog entitled "weather guard For Full-Size and Mini Vans." These devices are subject to Standard 125, Warning Devices (49 CFR @ 571.125). Accordingly, your company, as the manufacturer of these devices, must furnish the information specified in @ 566.5 within the time period specified in @ 566.6.

I hope you find this information helpful. If you have further questions, please contact Joan F. Tilghman of my staff at (202) 366-2992.

Sincerely,