Interpretation ID: aiam1643
Dubard & Vail
P.O. Box 38
Booneville
MS 38829;
Dear Mr. Dubard:This responds to your October 11, 1974, letter (JAH:nh asking whether a truck body manufactured in part before and in part after the effective date of Standard No. 121, *Air brake systems*, must conform to the requirements of that standard. Standard No. 121 becomes effective for trailers on January 1, 1975, and for trucks and buses on March 1, 1975.; Standard No. 121 applies to air brake-equipped trucks, buses, an trailers, but not to truck bodies, which we consider to be items of motor vehicle equipment. Therefore, if your client only makes and sells truck bodies, his products are not subject to Standard No. 121.; If your client combines a chassis- cab with a truck body, he may i many cases be manufacturing a new motor vehicle, and as such, be responsible for compliance with Federal motor vehicle safety standards. I have enclosed 49 CFR Parts 567, *Certification*, and 568, *Vehicles manufactured in two or more stages*, which set out the certification responsibilities of persons who manufacture vehicles in stages.; Section 568.8 states that a 'final-stage manufacturer' (frequently thi will be one who installs a truck body on a chassis cab) must certify the vehicle as conforming with all standards effective as of the date of manufacture of the 'incomplete vehicle,' the date of final completion, or any date between those two dates. The manufacturer makes this certification based both on documentation furnished by the incomplete vehicle manufacturer under S 568.4, and on the changes he has made to complete the vehicle.; Therefore, if your client completes a truck by adding a truck body t it, he must certify that the vehicle meets all applicable standards as of a date chosen by him within the specified period. For example, a vehicle completed by the addition of a body on March 15, 1975, which used a chassis-cab manufactured on February 1, 1975, could be certified as complying with all standards as of February 1, 1975. In this case, the vehicle would not be subject to Standard No. 121.; Yours truly, Richard B. Dyson, Acting Chief Counsel