Interpretation ID: aiam0216
President
The Auto Sun Products Company
529 - 543 Poplar Street
Cincinnati
OH 45214;
Dear Mr. Springer: Your letter of February 13 indicates that your understanding of th regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts.; Before you act on your understanding, however, you should give specia consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations;