United States Department of TransportationInterpretation ID: aiam1199
Managing Director
Truck Trailer Manufacturers Association
2430 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Calvin: This is in reply to your letter of July 5, 1973, requesting a unifor location for trailer certifications labels required by both the Hazardous Materials regulations (49 CFR S 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the 'forward half of the left side of the trailer.'; NHTSA Certification regulations, as you note, presently provide tha the certification label for trailers must be placed on the 'forward half of the left side of the vehicle' (49 CFR S 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to 'vehicle' in the language of the provision is considered inclusion of both. The Certification regulations therefore appear to permit the location of the label that you request.; I note, however, the drawings in your letter, those titled 'Acceptabl Locations of Certification Labels' and 'Suggested Locations for Certification Labels', picture as an appropriate label location the front of the vehicle.; This location is not permitted by the NHTSA Certification regulations which clearly call for the label to be affixed to the vehicle 'left side'. While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs;