Interpretation ID: GRUMMANOLSON.CRS

Mr. David White
Manager of Reliability
Gruman Olson Industries Inc.
1801 S. Nottawa Street
Sturgis, MI 49091

Dear Mr. White:

This responds to your letter of May 7, 2001, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on delivery trucks that Grumman Olson Industries is manufacturing for the U.S. Postal Service.

NHTSA's regulations at 49 CFR 567.4(c) prescribe specific locations for the installation of vehicle certification labels, and provide that if none of those locations are practicable, the manufacturer may suggest an alternate location for the agency's approval. Your letter states that during the first article inspection, the Postal Service requested that Grumman Olson Industries relocate the certification label to the dash shelf extension to the right of the instrument panel so that the driver can see the label from a seated position. Your letter further notes that because these vehicles are walk-in vans with removable sliding doors, placement of the label on the inward-facing surface of the door next to the driver's seating position would not be practicable. Your letter observes that the "[t]he proposed location is visible from almost all locations in the cab," and that the certification label can be easily found at this position in the event that any information that it contains is needed.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for the delivery trucks that Grumman Olson Industries is manufacturing for the U.S. Postal Service would meet this objective. NHTSA therefore approves your request.

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at 202-366-5238.

Sincerely,

John Womack
Acting Chief Counsel

ref:567
d.6/26/01