Interpretation ID: nht79-1.7

DATE: 10/24/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: VDO-ARGO Instruments Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. H. A. Ritzenthaler VDO-ARGO Instruments Inc. 980 Brooke Road P.O. Box 2630 Winchester, Virginia 22601

Dear Mr. Ritzenthaler:

This is in response to your letter of January 25, 1979, in which you stated your interpretation of Federal Motor Vehicle Safety Standard 127, Speedometers and Odometers, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct.

According to your interpretation of Safety Standard 127, those provisions which become effective for new motor vehicles on September l, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127).

Sincerely,

Frank Berndt Chief Counsel

U.S. Department of Transportation National Highway Traffic Safety Admin. 300 Seventh Street S.W. Washington, D.C. 20590 January 25, 1979

ATT: Mr. Richard B. Dyson, Acting Chief Counsel

Dear Mr. Dyson:

We are a manufacturer of automotive instruments, including speedometers. The changes required on speedometers for new cars after the effective dates September 1979 and September 1980 are clearly defined in Regulation 127, and our original equipment speedometers will be in compliance with this regulation.

We also have an obligation toward the automotive industry to supply original replacement parts for a period of ten years after manufacture of a particular vehicle model has ceased. These replacement parts for cars manufactured before the effective dates of Regulation 127 would, of course, not embody the changes called for in Regulation 127, nor does the regulation itself require such modifications in reference to replacement parts.

This is our interpretation of the applicability of Regulation 127. Should you feel that this interpretation would put us in violation of Regulation 127, please advise us accordingly.

Sincerely, VDO-ARGO INSTRUMENTS, INC.

H. A. Ritzenthaler Manager, Engineering

HAR/nf