Interpretation ID: nht71-2.30

DATE: 04/23/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: J.O. Phillips

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of March 31 you ask what requirements may apply to you if you rebuild truck tractors from salvage units.

To begin with, you become a "manufacturer" under the National Traffic and Motor Vehicle Safety Act of 1966, and subject to the requirements which the Act imposes upon manufacturers. These requirements are that you ensure that any motor vehicle you manufacture complies with all applicable Federal motor vehicle safety standards, that you cooperate with safety-related investigations by providing information and access to your premises upon request by this agency, that you furnish certification to distributers(Illegible Word) of your motor vehicles that the vehicles comply with applicable general standards, standards, and that you furnish notification to vehicle owners of any safety-related defects in the vehicle when they come to your attention. At present, regulations requiring that prospective purchasers be supplied with certain safety-related performance information do not apply to manufacturers of truck tractors.

Under our regulations a "truck tractor" is a sub-category of "truck," and therefore it must comply with Federal standards applicable to trucks, as well as requirements that specifically apply to truck tractors.(Illegible Word) standards, however, do not apply to vehicles in use, that is, to a vehicle which is merely repaired. A vehicle which is rebuilt, however, so that it becomes in(Illegible Word) motor vehicle must. In our view, comply with all Federal Standards applicable to the manufacturer of new vehicles.

You informed Mr. Vinaon of our Office of Chief Counsel on April 19 that, in a typical operation, you would assemble a truck tractor using both parts from one or more existing truck tractors and new parts contained in a "Glider" kit such as is held by(Illegible Words), and that the resulting truck tractor would be eligible for registration as a new motor vehicle. In our opinion, truck tractors which you produce in this manner must comply with all Federal standards applicable to trucks or truck tractors as of the date of their manufacture.

I enclose a copy of the Act and "Federal Motor Vehicle Safety Standards and Other Regulations" for your guidance.

Enclosures