Interpretation ID: nht71-3.30

DATE: 07/13/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: Grove Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 22, 1971, regarding the Tire Identification and Record Keeping Regulation (49 CFR 574).

You have asked if Grove Manufacturing Company is a "Motor Vehicle Manufacturer" within the meaning of section 574.10 of the regulation. As you indicated in your letter, you are the final-stage manufacturer of a truck mounted hydraulic crane, and as such, you are considered the vehicle manufacturer under section 568.3 of Vehicles Manufactured in Two or More Stages (49 CFR 568). As the vehicle manufacturer, you are required to maintain records of the name and address of the first purchaser of your vehicles, for purposes other than resale, along with a record of the tires on the vehicle at the time it is shipped.

Enclosed for convenience are copies of both regulations.

For your information, I would direct you to section 568.7 which allows an incomplete vehicle manufacturer to assume all the responsibilities of a manufacturer; this would include the record keeping responsibilities of Part 574.

If we can be of further assistance, please feel free to write.