Interpretation ID: nht67-1.23

DATE: 08/10/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Thermo King Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 11, 1967, regarding the applicability of the Federal Motor Vehicle Safety Standards to accessories which are purchased for installation after procurement of the car and, in particular, Safety Standard No. 201.

Standard No. 201, "Occupant Protection in Interior Impact -- Passenger Cars," applies only to vehicles as originally equipped and does not apply to accessories such as "after market" auto air conditioners. However, the public would certainly benefit from the maximum degree of conformance that may be feasible on after market installations.

It is sincerely regretted that a written response to your first request was not received by you and trust that you were not inconvenienced.

March 14, 1967

Dr. William Haddon Department of Commerce

As manufacturers of "after market" auto air conditioners, the National Traffic and Motor Vehicle Safety Act as passed on January 23, 1967, is of concern to us. Does this Safety Act apply to manufacturers of accessories which are purchased by the car owner after he receives the car? The case in point is a car owner which purchases an "add-on" auto air conditioner; must this accessory comply with Standard 201?

Recently one of our Engineers (Mr. D. Gregerson) contacted your office (Clayboure) and received verbal "no" answers to the above questions. Your aides mentioned that this could be confirmed by requesting it by letter. We would appreciate this confirmation when convenient for you.

Very truly yours,

L. L. Willis Vice President - Engineering