Interpretation ID: aiam3264
Manager of Engineering Services
Truck Body and Equipment Association
Inc.
5530 Wisconsin Avenue
Suite 1220
Washington
DC 20015;
Dear Mr. Forrester: This responds to your March 17, 1980, letter asking for a interpretation of the certification label requirements as they apply to a manufacturer who performs some manufacturing operation on a stripped chassis. You indicated in your letter that the stripped chassis is not a chassis-cab and, therefore, does not have a certification label. You further stated that the second manufacturer's modification of the stripped chassis do (sic) not convert it to a chassis-cab.; The chassis certification label requirements of Part 567 *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*, apply only to chassis-cabs as that term is defined in Part 567. Since the incomplete vehicle to which you refer is not a chassis-cab at either of the first two stages of its manufacture, it is not required to be labeled. The second manufacturer is required to amend the incomplete vehicle document where necessary to show the effects of its changes to the incomplete vehicle.; Your second question poses a similar hypothetical, except that th second manufacturer completes the incomplete vehicle to the point where it is a chassis-cab. In this instance, the second manufacturer is required to attach the chassis-cab certification label. Also, all necessary amendments must be made in the incomplete vehicle document.; Sincerely, Frank Berndt, Chief Counsel