Interpretation ID: nht69-2.25

DATE: 09/18/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: E. D. Etnyre & Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 30, 1969, to the Federal Highway Administration, that has been referred to this office. In your letter you ask for a yes or no answer to specific questions relative to certification of assemblies completed from chassis-cabs. The answers to your questions follow: 1. QUESTION: "We manufacture bodies that are sold through a non-exclusive dealer that sells construction equipment.

The dealers sale includes only the body and its mounting on a chassis-cab. The chassis-cab is furnished by the customer and is normally purchased through a second dealer that handles truck sales. The chassis-cab is delivered to our factory for the mounting of the body. Do we supply certification for the completed vehicle?" ANSWER: The answer to your first question is yes, you would supply certification to the dealer or distributor at the time of delivery of the vehicle. 2. QUESTION: "If the answer to the first question is yes, do we remove the temporary certification label on the chassis cab (367.5), write the chassis-cab vehicle identification number on this and place this in our file as evidence that the vehicle we assemble has been furnished with a certified chassis-cab?" A simple yes or no answer cannot be given to question No.

ANSWER: 2.

The method you use in procuring and retaining information relative to the chassis-cab would be up to you. The procedure you describe, writing the chassis-cab identification numbers on the label and placing some in your file would be considered satisfactory.

3. QUESTION: "With reference to the vehicle identification number, paragraph 267.4(g)(4), do we supply only our vehicle identification (or serial0 number?" ANSWER: yes, you would only supply your vehicle identification (or serial) number in accordance with Part 367.4(g)(2) of the regulation. 4. QUESTION: "Paragraph 367.4(g)(2) requires the month and year of manufacture. It further states "This shall be the time during which work was completed at the place of main assembly of the vehicle." In a previous response to a letter of ours signed by Mr. F. C. Turner and addressed to Senator Charles Persy (copy enclosed). Mr. Turner stated that a FHWA ruling stated that a completed assemblege need only conform to the standards that were in effect at the time of completion of the chassis-cab.

requirement will be the month and year of manufacture as stated on the label in paragraph 367.5." ANSWER: Yes, the month and year of manufacture of the chassis-cab would be used to satisfy the requirements of 367.4(g)(2), month and year of manufacture.

We trust this will clarify the situation for you