Interpretation ID: nht88-4.15

TYPE: INTERPRETATION-NHTSA

DATE: 11/24/88

FROM: MARTIN M. GINSBURG -- PROLINE DESIGNS

TO: ERICA JONES -- CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/27/89 FROM STEPHEN P. WOOD -- NHTSA TO MARTIN M. GINSBURG -- PROLINE DESIGNS; REDBOOK A33; STANDARD 126; STANDARD 302 LETTER DATED 05/08/88 FROM MARTIN M. GINSBURG TO ERIKA JONES -- NHTSA; OCC 2027

TEXT: Dear Ms. Jones:

I am requesting a legal interpretation concerning Motor Vehicle Standard No. 302 and whether or not my product must comply.

The product consists of interior window coverings for pick up truck shells. The shell is a segregated area from the cab. It is placed directly over the bed of the truck. There are no seats in the bed, and the shell is installed as an after market prod uct. The window coverings are made out of an apparel type material.

Am I required to comply with this regulation? Alternatively, if I have the product treated with California Health and Safety Code Standard No. 19, and if I send you a copy of the Standard, could you determine if I have met the No. 302 Standard.

Sincerely,