Interpretation ID: nht68-1.22

DATE: APRIL 26, 1968

FROM: AUTHOR UNAVAILABLE; William H. Risteen; NHTSA

TO: Halfpenny, Hann and Ryan

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 6, 1968, to Mr. Lowell K. Bridwell, has been referred to me for reply.

In regard to your question, "Can a car dealer install equipment for which no standards have been established (such as air conditioning units) on a motor vehicle without violating the National Traffic Motor Vehicle Safety Act of 1966?", we are pleased to provide the following clarification.

The fact that there is not a standard directly applicable to air-conditioners or other items of equipment does not mean the dealer has no responsibility under the Act if he installs these equipment items. Any modification to the vehicle before the first purchase for purposes other than resale, must not alter the existing compliance of the motor vehicle with applicable standards.

In the case of an air-conditioner, if it is installed in the instrument panel or any other part of the interior of a passenger car covered by Standard No. 201, it would have to comply with the requirements of the Standard.

I hope this response clarifies the matter with you.