Interpretation ID: nht76-3.22

DATE: 07/27/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Plymouth Fire Department

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 22, 1976, request to know when Standard No. 121, Air Brake Systems, became applicable to firefighting vehicles, and whether the date of manufacture of the chassis or the date of manufacture of the completed vehicle is relevant for purposes of the standard's applicability. You also ask whether the chassis manufacture or the final manufacturer who completes the vehicle is responsible for complying with applicable safety standards.

Standard No. 121 applies to firefighting vehicles manufactured on or after June 1, 1976. I have enclosed a copy of the standard, which includes a listing of effective dates in section S3, Applicability.

Because most trucks are manufactured in two or more stages, the NHTSA has issed a regulation that assigns responsibilities to the incomplete vehicle manufacture, intermediate manufacturers, and the final-stage manufacturer for ensuring conformity of the vehicle with safety standards (Part 568, Vehicles Manufactured in Two or More Stages (49 CFR Part 568)). Section 568.6 of this regulation requires that the final-stage manufacturer complete the vehicle in such a manner that it conforms to applicable standards. Section 568.6 does permit the final-stage manufacturer to treat as the time that manufacture is "completed" for the purposes of certification any date no earlier than the manufacturing date of the complete vehicle and no later than the date of completion of final-stage manufacture. For example, a firefighting vehicle that is completed on a chassis built before June 1, 1976, could be legally completed by a final-stage manufacturer at any future date without conformity to Standard No. 121.