Interpretation ID: nht71-5.23

DATE: 12/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of September 15, 1971, requesting our interpretation of certain motor vehicle safety standards and regulations:

1. Federal Motor Vehicle Safety Standard No. 206, "Occupant Crash Protection," as amended at 36 F.R. 4600 (March 10, 1971). If trucks over 10,000 pounds(Illegible Word) are equipped with a seat belt system(Illegible Word) in paragraph S4.3.2, the vehicles need not meet the requirements of paragraphs S5 and S6, which apply only when the complete passive protection system option of paragraph S4.3.1 is adopted. Of course, the seat belt system must conform to the seat belt assembly requirements of Federal Motor Vehicle Safety Standard No. 209, "Seat Belt Assemblies."

2. Federal Motor Vehicle Safety Standard No. 206, "Door Locks and Door Retention Components." Your interpretation of the standard's coverage is correct: there are no requirements in the standard for the installation of the latches and hinges.

3. Part 573, "Defect Reports," 36 F.R. 3064 (February 17, 1971). The National Traffic and Motor Vehicle Safety Act and our regulations do not require manufacturers to repair defective motor vehicles. Manufacturers are therefore free to make whatever arrangements for repair of defects they wish. Of course, we hope that in making such arrangements the manufacturers will assume the responsibility of assuring that the repairs are made properly.