Interpretation ID: 86-2.31

TYPE: INTERPRETATION-NHTSA

DATE: 04/22/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: S.H. Jacobs

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. S. H. Jacobs Product Manager Robert Bosch Corporation P.O. Box 4601 North Suburban, IL 60198

Dear Mr. Jacobs:

This responds to your letter dated December 6, 1985, inquiring whether any Federal motor vehicle safety standards apply to spark plugs. regret the delay in responding to your inquiry.

Under the National Traffic and Motor Vehicle Safety Act of 1966, as amended, 15 U.S.C. 1391, et seq. (the Act), this agency has the authority to establish safety standards for motor vehicles and their equipment. At this time, none of these standards is applicable to spark plugs.

You should note that under Part B of the Act and our regulations, manufacturers of motor vehicle equipment, such as spark plugs, have the responsibility to conduct notification and remedy campaigns for safety-related defects in their products. I have enclosed an information sheet outlining our defect and other regulations.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Department of Transportation National Highway Traffic Safety Administration Office of Chief Consul Washington, D.C. 20590

December 6, 1985

Subject: DOT/NHTSA Standards and Requirements for the Sale of Spark Plugs

Dear Sirs,

As per our letter dated October 9, 1985, it is our understanding there are not any DOT/NHTSA standards and/or regulations governing the sale of spark plugs (copy attached). However, we require a written reply from your department confirming the non-existence of any DOT/NHTSA standards and/or regulations regarding the sale of spark plugs.

Our customer requires a written confirmation as soon as possible. Your immediate attention to this matter will be appreciated.

Sincerely, Attachment

S.H. Jacobs Product Manager

cc: ASD - L. Milligan

Department of Transportation National Highway Traffic Safety Administration Office of Chief Consul Washington, D.C. 20590 October 9, 1985

Subject: DOT/NHTSA Standards and Requirements for the Sale of Spark Plugs

Dear Sirs,

The Robert Bosch Corporation sells spark plugs through K-Mart stores across the country. One of the conditions for this sale is that our product conforms in all respects with all applicable federal, state and local laws, orders and regulations, including but not limited to those regarding occupational safety and health".

After conversations with various DOT and NHTSA personnel, It is our understanding there are not any DOT/NHTSA standards and/or regulations covering the sale of spark plugs.

Enclosed is a copy of the letter from K-Mart requesting such documentation for your review.

We request a written reply confirming the non-existence of any DOT/ NHTSA standards and/or regulations regarding the sale of spark plugs.

Your prompt attention to this matter is appreciated.

Sincerely,

S. H. Jacobs Product Manager

cc: AMA J. Crowley ASD L. Milligan