Interpretation ID: nht80-2.29

DATE: 05/01/80 EST

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSR INTERPRETATION

TEXT:

NOA-30

Mr. Hisakazu "Kazu" Murakami Nissan Motor Co., Ltd. Suite 707 1919 Pennsylvania Avenue, N.W. P.O. Box 57105 Washington, D.C. 20037

Dear Mr. Murakami:

This responds to your April 8, 1980, letter asking how you should modify labels that you incorrectly installed on approximately 4,000 chassis-cabs. The labels that you installed state that the vehicle conforms to all applicable safety standards, and this is not true. In a subsequent telephone conversation with Roger Tilton of my staff, you indicate that your company would be willing to install correct certification labels over the old incorrect labels by the use of adhesives.

The National Highway Traffic Safety Administration concludes that your suggested attachment of new labels over the old labels would be sufficient to bring the chassis-cabs into compliance with the regulations. As you know, the new labels must be permanently attached and not easily removable. Also, we would require that the new labels completely cover the old labels, and that the incorrect information from the old labels not be legible through the new labels. If your proposal meets these two requirements, we would accept this as a satisfactory solution. We do ask that you notify us when you have completed the relabeling process.

Sincerely,

Frank Berndt Chief Counsel

April 8, 1980

Mr. Roger S. Tilton (NOA-30) Office of Chief Council National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Tilton:

This letter is regarding the telephone conversation you had with Mr. Hisakazu Murakami on April 7, 1980 concerning the problem written below.

We, Nissan Motor Company, Ltd., mistakenly attached the wrong certification label, which is required by Part 567, on our 1980 Model Datsun Chassis-Cab Vehicle (Datsun 720). The wrong label reads: "This Vehicle Conforms to all Applicable Federal Motor Vehicle Safety Standard in Effective in ." However, the label should read: "This Chassis-Cab Conforms to Federal Vehicle Safety Standards Nos. ."

We are sure that the correct labels will be attached on the Chassis-Cabs which are located at our assembly plants and also the ones that are now in the process of being shipped to the U.S.A. However, there are approximately 4,000 or less Chassis-Cabs which have been sold to dealers or so called body builders which have the wrong label. We believe it may be possible for us to submit all of the VIN numbers for the Chassis-Cabs which bear the wrong labels.

We would be willing to make our best efforts based on your recommendations concerning this matter. I would appreciate it if you would contact Mr. Hisakazu Murakami, a member of my staff, at (202) 466-5284 concerning what necessary steps we should take.

Very truly yours,

NISSAN MOTOR COMPANY, LTD.

Teruo Maeda General Manager