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Interpretation ID: nht69-1.38

DATE: 03/24/69

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Patton; Blow; Verrill; Brand & Boggs

TITLE: FMVSR INTERPRETATION

TEXT: This refers to your letter of February 14 concerning the problems faced by some members of the boat trailer manufacturing industry in complying with the Administration's certification regulations (49 C.F.R. Part 367).

As I understand the problem, it is that manufacturers of boat trailers sometimes ship the trailers to their dealers as "knocked down" components, in the form of kits containing all the parts necessary to construct a boat trailer and instructions for the trailer's assembly. I also understand that the kits are not packaged, but are held together by steel bands or similar devices.

In the circumstances described above, it is my opinion that a manufacturer of boat trailers would not violate the certification regulations if he affixed the certification label required by section 367.4 of the regulations to a component of the trailer so that, when the trailer is assembled in accordance with the manufacturer's instructions, the label will appear on the forward half of the left side of the trailer such that it is easily readable without moving any part of the trailer.

If a trailer is shipped in assembled form, of course, the certification label must be affixed to it in the location specified by section 367.4(d).

If I can be of further assistance to you, please do not hesitate to ask me for it.