Interpretation ID: 1982-2.16
DATE: 06/23/82
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Grebe; Gross; Jensen & Peek; P.C. -- J. Mack Shively
TITLE: FMVSS INTERPRETATION
TEXT: Grebe, Gross, Jensen & Peek, P.C. 1530 S.W. Taylor Street Portland, Oregon 97205
This is in response to your letter of May 11, requesting our views as to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.
You are correct in your interpretation of the manner in which our requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.
Sincerely,
Frank Berndt Chief Counsel
Office of Chief Counsel
RE: Manufacturer Identification Cranston Diversified Industries, Inc.
Dear Sirs:
My client, Cranston Diversified Industries, Inc., is currently negotiating with the patent holder to construct a semi-trailer which can be converted from a "flat" to a "drop center" trailer configuration. The design utilizes interchangeable front, rear, and center sections.
I have concluded that pursuant to 49 C.F.R ampersand 571.155, Standard No. 115, S4.1, each vehicle manufactured requires only one vehicle identification number. I have also concluded that the label to be attached to each trailer should be affixed to the left side of the front section (the hitch structure) and that only one label is required pursuant to 49 C.F.R. ampersand 567.4(d).
Please advise me as to whether my interpretation of your Regulations is correct. I have enclosed a copy of the Letters Patent of the United States issued for the trailer which include a detailed description of its structure.
Thank you very much for your attention to this matter.
Sincerely,
J. Mack Shively JMS:vs Enclosures cc: Cranston Diversified Industries, Inc.