Interpretation ID: nht73-3.7

DATE: 01/03/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Messrs. Carter and Carter

TITLE: FMVSR INTERPRETATION

TEXT: This is reply to your letter of December 14, 1972, to the Federal Highway Administration on behalf of your client, a snow plow dealer. You ask for verification "that the addition of a snow plow to a completed truck is considered the addition of a readily attached component and does not require recertification."

We confirm that a person adding a snow plow to a completed truck is not a final-stage manufacturer who is required by 49 CFR Part 568 to certify compliance of the vehicle with Federal motor vehicle safety standards. He is, however, responsible for insuring that the modified vehicle complies with Standard No. 108 before delivering it to its purchaser.