Interpretation ID: nht76-3.3

DATE: 05/05/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your April 14, 1976, letter concerning the meaning of the effective dates of Federal motor vehicle safety standards.

You are correct in your understanding that a vehicle's date of sale is irrelevant to a determination of which standards are applicable to it. 49 CFR @ 571.7(a), Applicability, specifies in relevant part:

. . . each standard . . . applies according to its terms to all motor vehicles or items of motor vehicle equipment the manufacturer of which is completed on or after the effective date of the standard.

For vehicles that you complete by mounting a body on a chassis, you are permitted by 49 CFR @ 567.5(a) (7) to treat as the time that manufacture is "completed" for the purposes of @ 571.7(a) any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture, regardless of when the body or chassis was sold. Please note that you must be consistent in your choice of completion date, e.g., you may not choose one date to determine applicability of certain standards while choosing another date for other standards.