Interpretation ID: nht80-2.16

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

APR 24 1980 NOA-30

Mr. James E. Forrester Manager of Engineering Services Truck Body and Equipment Association, Inc. 5530 Wisconsin Avenue, Suite 1220 Washington, D.C. 20015

Dear Mr. Forrester:

This responds to your March 17, 1980, letter asking for an interpretation of the certification label requirements as they apply to a manufacturer who performs some manufacturing operation on a stripped chassis. You indicated in your letter that the stripped chassis is not a chassis-cab and, therefore, does not have a certification label. You further stated that the second manufacturer's modification of the stripped chassis do not convert it to a chassis-cab.

The chassis certification label requirements of Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages, apply only to chassis-cabs as that term is defined in Part 567. Since the incomplete vehicle to which you refer is not a chassis-cab at either of the first two stages of its manufacture, it is not required to be labeled. The second manufacturer is required to amend the incomplete vehicle document where necessary to show the effects of its changes to the incomplete vehicle.

Your second question poses a similar hypothetical, except that the second manufacturer completes the incomplete vehicle to the point where it is a chassis-cab. In this instance, the second manufacturer is required to attach the chassis-cab certification label. Also, all necessary amendments must be made in the incomplete vehicle document.

Sincerely,

Frank Berndt Chief Counsel

17 March 1980

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Attention: Roger Tilton

Gentlemen:

The purpose of this letter is to confirm your oral interpretation of certification procedures involving stripped chassis and chassis cabs. A member of TBEA plans to modify stripped chassis and is seeking guidance as to the proper procedures.

Your interpretation was that:

(1) In the case where they start with a stripped chassis and do work that does not cause it to become a chassis cab, their only responsibility under Parts 567 and 568 is to provide an addendum to the incomplete vehicle document as described in Part 568. No certification label is required in this instance.

(2) Where they start with a stripped chassis and their work results in the incomplete vehicle being classified as a chassis cab then they are considered the chassis cab manufacturer and are required to:

(a) provide an addendum to the incomplete vehicle document (Part 568)

(b) attach a certification label which contain the statements of Part 567.5a

The location of the certification label must be in accordance with Part 567, Certification.

Your written confirmation of the above is requested.

Sincerely yours,

James E. Forrester Manager of Engineering Services