Interpretation ID: 2866yy
Manager, Compliance and Technical Legislation
Volvo GM Heavy Truck Corporation
7825 National Service Road
P.O. Box 26115
Greensboro, NC 27402-6115
Dear Mr. Lawrence:
This responds to your letter of June 15, 1990 concerning replacement doors. I apologize for the delay in our response. You quote an April 9, l990 interpretation letter to Mr. Rowghani concerning Standard No. 214, Side Door Strength. You note that the letter states that "there is no requirement that the replacement door restore the vehicle to a condition in which it continues to meet Standard No. 214." You requested a clarification of this statement as you believe that the "render inoperative" provision of Section 108(a)(2)(A) of the Act would require "installation of parts meeting the same performance requirements as OEM parts."
The "render inoperative" provision of section 108(a)(2)(A) would prohibit any manufacturer, dealer, distributor, or repair business from removing and replacing an undamaged side door, unless the vehicle continued to comply with Standard No. 214. However, that section does not require a manufacturer, dealer, distributor, or repair business to return a vehicle to compliance with a standard if it has been "rendered inoperative" by another agent, such as a crash. The sentence you quote begins, "if damage to a vehicle is such that its original door must be replaced." The interpretation was intended to be limited to situations where damage is so extensive that the vehicle would no longer comply with Standard No. 214.
I hope you find this clarification helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel /ref:VSA108, 214 d:3/l3/9l