Interpretation ID: 1982-3.1

TYPE: INTERPRETATION-NHTSA

DATE: 08/16/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Hon. John Glenn - US Senate

TITLE: FMVSR INTERPRETATION

TEXT:

16 AUG 1982 NOA-30

The Honorable John Glenn United States Senator 200 North High Street, Suite 600 Columbus, Ohio 43215

Dear Senator Glenn:

This responds to your July 1, 1982, letter enclosing correspondence from your constituent Mr. Donald M. Robinson. Mr. Robinson would like to know whether Federal regulations prohibit him from purchasing a pickup cab and chassis without the body attached. The answer to his question is no.

The National Highway Traffic Safety Administration only requires that all vehicles be manufactured in compliance with the applicable motor vehicle safety standards. We have no requirement, nor do we know of any other Federal regulation, that would prevent Mr. Robinson from purchasing just the cab and chassis of a vehicle that he desires. When he adds his own utility body to the cab and chassis, he would become the final-stage vehicle manufacturer and would be required to certify that the completed vehicle complies with all applicable Federal safety standards. I am enclosing copies of the regulations pertinent to such an operation.

If I can be of further assistance to you or Mr. Robinson, please contact me.

Sincerely,

Frank Berndt Chief Counsel

Enclosures: Constituent's Correspondence 49 CFR Parts 567 & 568

cc: Washington Office

June 23, 1982

Senator John H. Glenn 200 N. High Street, Room 6 Columbus, Ohio 43215

We have asked truck dealers in the area for bids on two one-half ton cab and chassis and one three-quarter ton cab and chassis trucks upon which we intended to install utility beds so that the trucks would be equipped properly to be used as service trucks on our distribution system.

We have been told by the dealers that they cannot order just the cab and chassis but have to include the pickup bed for which we have absolutely no use. This is our first knowledge of this and, quite frankly, it shocks me.

We are told that this is a federal law, regulation or whatever.

Could you check into this matter at your convenience to see if there is any recourse.?

We will appreciate whatever you can do.

Yours truly,

Donald M. Robinson Manager

DMR/mb