Interpretation ID: nht75-3.22

DATE: 07/03/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Steer Safe Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 22, 1975, in which you request a ruling that a person who installs a "Steer Safe" steering stabilizer is not required to recertify the vehicle in which it is installed. You refer to a letter to Safety Products, Inc., dated August 24, 1972, in which it was stated that we would accept a determination that the installation of a steering stabilizer manufactured by Safety Products did not constitute remanufacturing, and that a person who installed such a device need not recertify the vehicle on which it is installed.

Since that letter, the National Highway Traffic Safety Administration has issued regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. These regulations (49 CFR @@ 567.7 and 567.8; copy enclosed) supersede opinions such as the one we provided Safety Products, which was based solely on the more general provisions of the National Traffic and Motor Vehicle Safety Act and the certification regulations in effect at that time. Under the new regulations, which were effective February 1, 1974, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than "readily attachable" components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.

From the description of your device, with the enclosed (Illegible words) to require no special expertise or special (Illegible words). It would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that it is "readily attachable", and that an alterer label is not required when a "Steer Safe" steering stabilizer is installed.