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Interpretation ID: nht76-5.31

DATE: 11/01/76

FROM: CHARLES E. DUKE FOR JOHN W. SNOW -- NHTSA

TO: House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your September 20, 1976, letter concerning record keeping with respect to new passenger cars that are damaged prior to retail sale.

I would like to clarify the discussion of record requirements in my September 14, 1976, letter to you. While the National Highway Traffic Safety Administration (NHTSA) does not require vehicle manufacturers to create records of safety-related repairs that are made to new motor vehicles prior to sale, we do require the retention of all such records that are in fact created by the manufacturer. Through such records, the NHTSA can in many cases trace the history of vehicles suspected of containing safety-related defects. We have not to date found a safety need sufficient to justify further requirements specifically regarding identification of the vehicles in question.

A copy of the record retention regulation, 49 CFR Part 576, is enclosed for your convenience.