Interpretation ID: nht68-4.10

DATE: 09/03/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Officine Alfieri Maserati S.p.A.

TITLE: FMVSR INTERPRETATION

TEXT: This is in responce to your letter of August 8 with reference to compliance of the Maserati automobile with Federal motor vehicle safety standards.

You have asked first of all whether, as a manufacturer of 620 vehicles in 1967, Mascrati may be excused from compliance with some of the Federal standards. The National Traffic and Motor Vehicle Safety Act of 1966, under which Federal standards are issued, was recently amended to authorize a procedure whereby manufacturers of limited production vehicles might petition for examption from the Federal standards. But this procedure is not available to a manufacturer of more than 500 vehicles a year, no matter how few vehicles of that manufacturer are exported to the United States. Consequently Maserati cannot be exempted from any of the Federal standards.

You have also mentioned the difficulties that a small manufacturer face in crash-testing vehicles, and have asked whether the photographs you submitted showing several Mascrasti automobiles which have been involved in front and collisions are acceptable as proof of compliance with Federal standard No. 204 (Steering Control Rearward Displacement - Passenger Cars). I hope the following explanstion will be of assistance to you. The Federal standards do not require crash-testing of vehicles, nor the submission of any data to the Federal Highway Administration for "approval". What is required is that a manufacturer attach a certification on plate to his vehicle stating that the vehicle conforms to all applicable Federal standards on the date of the vehicle's manufacture. How the manufacturer satisfies himself that the vehicle conforms is his own affair; he may have non-crash data or other information which indicates conformance. The Federal Highway Administration, however, may requests this date if through its own investigation it appears that a certification is false or misleading, and that a vehicle does not actually conform to a standard.

I enclose a copy of the latest Federal standards for your guidance.