Interpretation ID: nht69-1.40

DATE: 08/26/69

FROM: AUTHOR UNAVAILABLE; David E. Wells; NHTSA

TO: Challenge-Cook Bros. Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 12, 1969, concerning the responsibility of manufacturers who assemble work bodies such as concrete mixers to chassis-cabs produced by another company. You stated:

"We understand that in the case of installing concrete mixers of our manufacture on a chassis vehicle, our certification will cover only those Safety Standards relating to our own equipment and its installation, plus modifications, if made by us to the chassis vehicle in the area where Safety Standards apply."

As a final-stage assemblier you are responsible for any standards applicable to the completed vehicle to which conformity has not been certified by the chassis-cab manufacturer, and for any standards conformity to which is affected by the addition of the body. The chassis-cab manufacturer is required to affix a label listing the standards the chassis-cab conforms to. If the list includes all relevant standards, and you have no specific knowledge that the chassis-cab may not conform (as, for example, where it has been damaged in transit), then your statement above is essentially correct.

The relevant rulings are contained in the Federal Register notices of January 3, 1968, together with the certification regulations published July 9, 1969. Copies are enclosed.