ID: nht91-1.44

DATE: February 19, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Walter E. Gundaker -- Acting Director, Center for Devices and Radiological Health, Food and Drug Administration

TITLE: None

ATTACHMT: Attached to letter dated 12-26-90 from Walter E. Gundaker to Paul Jackson Rice (OCC 5576)

TEXT:

This responds to your December 26, 1990 letter concerning mechanical hand and foot driving controls. These controls are intended to enable persons who have limited use of their arms or legs to drive a motor vehicle. In your letter you stated that, because these controls raise questions regarding motor vehicle safety, your agency would like to revoke their present classification as a class II medical device. However, before you do this, you would "need assurances that these driving controls for handicapped persons do fall in the jurisdiction of NHTSA and that significant complaints of malfunction would be investigated by NHTSA." The following is a summary of our statutory authority in this area.

Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. The driving controls that are the subject of your letter would be considered items of motor vehicle equipment, within the meaning of the Safety Act. However, this agency has not issued any standards setting forth performance requirements for controls for disabled drivers. Obviously, these controls could not be determined to be in noncompliance with a safety standard if there is no applicable safety standard.

Another possible source of authority for NHTSA would be S108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)), which specifies that, no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard." This statutory prohibition would be violated if a manufacturer, distributor, dealer, or repair business installed a mechanical hand or foot driving control so as to "render inoperative" any of the elements of design installed in the original vehicle in compliance with one of our safety standards. However, when NHTSA has been asked about this in the past, the agency has generally stated that it would not institute enforcement proceedings under section 108(a)(2)(A) of the Safety Act against dealers or repair shops when a particular vehicle must be modified to accommodate the needs of a particular disability.

Finally, the agency has authority to investigate allegations that items of motor vehicle equipment, such as these controls, contain defects related to motor vehicle safety, and to order the equipment manufacturer to notify owners and to remedy without charge any items of equipment determined to contain a defect related to motor vehicle safety, as provided in sections

151-160 of the Safety Act (15 U.S.C. 1411-1420). If there were indications that these controls contained a defect related to motor vehicle safety, the agency would investigate and take appropriate actions. Of course, as with any investigation of alleged safety-related defects, the outcome would depend on the facts of the specific investigation.

I hope you find this information helpful. If you have further questions or need some additional information in this area, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

ID: 23257.ztv

Mr. Larry Hughson
Vehicle Services Division
2835 N. Kerby Avenue
Portland, OR 97227





Dear Mr. Hughson:

This is in reply to your e-mail of June 18, 2001, to the National Highway Traffic Safety Administration's Region 10 asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

You have been informed by a member of the public that Portland's police cars do not comply with Standard No. 108. You cite that portion of S5.5.4 of Standard No. 108 which states that "the high-mounted stop lamp on each vehicle shall be activated only upon application of the service brakes." You state that S5.5.10 does not list the center high-mounted stop lamp, backup lamps, stop lamps, and headlamps (for purposes other than signaling) as lamps that are allowed to flash. You also cite S5.5.10(d) which, in effect, requires these lamps to be steady burning when in use. You ask if there is an alternate standard that applies to police vehicles, or whether police cars are exempt from this requirement.

We surmise from your letter that the police vehicles are equipped with a system that flashes headlamps, stop lamps, the center high-mounted stop lamp, and backup lamps for emergency purposes.

You did not relate whether this lighting system is installed as original equipment or after the vehicles are delivered to the police. I will first address its installation as original equipment. I enclose a copy of a letter that we sent Col. W. Gerald Massengill of the Virginia State Patrol on July 3, 2001, which we believe is applicable to the questions you raise. In brief, the system you describe on Portland's vehicles does not comply with Standard No. 108. However, we traditionally defer to the judgment of a State as to the installation and use of emergency lighting devices on its vehicles. The drivers that operate police vehicles will be instructed to use the warning system only under certain circumstances, such as to alert motorists of the presence of stopped vehicles in the roadway ahead. In all other circumstances, the headlamps, stop lamps

and backup lamps will operate consistent with the requirements of Standard No. 108. The noncompliances are temporary in nature and are necessary for the mission of the police. We believe, then, that the emergency system you describe is permissible as original equipment because of the circumstances which are unique to law enforcement.

If the system is added after the vehicles are delivered to the police department, please note that Federal law (49 U.S.C. 30122), does not prohibit a vehicle owner from adding equipment that may create a noncompliance with a Federal motor vehicle safety standard. Thus, installation of the warning system by a city-owned and operated garage is not prohibited under Federal law if installed only on city-owned vehicles. If the installation of the warning system is by a motor vehicle repair business, other than one that is city-owned, we would also consider that permissible for the same reasons as we would allow the system as original equipment.

If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263)..

Sincerely,

John Womack
Acting Chief Counsel

Enclosure
Ref:108
d.7/30/01

ID: nht94-3.33

TYPE: INTERPRETATION-NHTSA

DATE: June 9, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: William L. Blake -- Esq.

TITLE: None

ATTACHMT: Attached To Letter Dated 5/11/94 From William Blake To Department Of Transportation and Letter Dated 4/29/94 From William Blake To United States Department Of Transportation

TEXT: Dear Mr. Blake:

This responds to your letters of April 29 and May 11, 1994, to the Department of Transportation with respect to the importation of replacement parts for a 1985 Mercedes-Benz 280SL that was not originally manufactured to conform to Federal bumper requirem ents, and which, apparently, was not conformed after importation to comply with those requirements. Your client, who owns such a vehicle, has been informed that "it is illegal to import bumper parts which do not conform to United States crash standards and that accordingly the entire bumper must be replaced. . . ." You have asked whether it is legal to import "European bumper parts" for the vehicle in question, and for us to provide you with citations to appropriate statutes and regulations.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act, 15 U.S.C. 1381 et seq..) and bumper standards under Title I of the Motor Vehicle Information and Cost Savings Act (Cost Savings Act, 15 U.S.C. 1901 et seq.). NHTSA is authorized to issue safety standards and bumper standards for new motor vehicles and new motor vehicle equipment. All motor vehicle s and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards and bumper standards.

NHTSA has issued one bumper standard, which is set forth at 49 CFR Part 581. The standard was issued under the joint authority of the Safety Act and the Cost Savings Act. While the agency has the authority to issue bumper standards for both passenger mo tor vehicles and passenger motor vehicle equipment, it has to date only issued a bumper standard for motor vehicles. There is no applicable standard that replacement bumper components must meet, and, because of this, no prohibition against importation o f bumper system components which differ from those required for a vehicle to comply with

2

Part 581. I note that this is reflected in the lack of any provision in our importation regulation, 49 CFR Part 591, requiring conformance of imported bumper parts.

Your second question is whether it is illegal for an owner "to participate in the installation of bumper parts which do not conform to United States standards." As we have seen, no Federal standards apply to replacement bumper parts. This means that it is not illegal for an owner or anyone else to participate in the installation of equipment that is intended to replace original bumper equipment on vehicles that were not manufactured to conform to U.S. bumper requirements. As a matter of interest, our records do not indicate that the importer of the vehicle in question, WDB1070421A026883, failed to conform it to Part 581, but we cannot verify this as the conformance documentation for the vehicle no longer exists.

Sincerely,

ID: 0009-2

William L. Blake, Esq.
900 Rockefeller Building
614 Superior Ave., N.W.
Cleveland, OH 44113

Dear Mr. Blake:

This responds to your letters of April 29 and May 11, 1994, to the Department of Transportation with respect to the importation of replacement parts for a 1985 Mercedes-Benz 280SL that was not originally manufactured to conform to Federal bumper requirements, and which, apparently, was not conformed after importation to comply with those requirements. Your client, who owns such a vehicle, has been informed that "it is illegal to import bumper parts which do not conform to United States crash standards and that accordingly the entire bumper must be replaced . . . ." You have asked whether it is legal to import "European bumper parts" for the vehicle in question, and for us to provide you with citations to appropriate statutes and regulations.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act, 15 U.S.C. 1381 et seq.) and bumper standards under Title I of the Motor Vehicle Information and Cost Savings Act (Cost Savings Act, 15 U.S.C. 1901 et seq.). NHTSA is authorized to issue safety standards and bumper standards for new motor vehicles and new motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards and bumper standards.

NHTSA has issued one bumper standard, which is set forth at 49 CFR Part 581. The standard was issued under the joint authority of the Safety Act and the Cost Savings Act. While the agency has the authority to issue bumper standards for both passenger motor vehicles and passenger motor vehicle equipment, it has to date only issued a bumper standard for motor vehicles. There is no applicable standard that replacement bumper components must meet, and, because of this, no prohibition against importation of bumper system components which differ from those required for a vehicle to comply with

Part 581. I note that this is reflected in the lack of any provision in our importation regulation, 49 CFR Part 591, requiring conformance of imported bumper parts.

Your second question is whether it is illegal for an owner "to participate in the installation of bumper parts which do not conform to United States standards." As we have seen, no Federal standards apply to replacement bumper parts. This means that it is not illegal for an owner or anyone else to participate in the installation of equipment that is intended to replace original bumper equipment on vehicles that were not manufactured to conform to U.S. bumper requirements. As a matter of interest, our records do not indicate that the importer of the vehicle in question, WDB1070421A026883, failed to conform it to Part 581, but we cannot verify this as the conformance documentation for the vehicle no longer exists.

Sincerely,

John Womack Acting Chief Counsel ref:581#591#CSA d:6/9/94

ID: 2343y

Herr Tilman Spingler
Robert Bosch GmbH
Postfach 42
7410 Reutlingen
W. Germany

Dear Herr Spingler:

This is in reply to your FAX to Richard Van Iderstine of this agency, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

Your first question is:

1) To turn the adjusting screws of a HB-2 headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?

Section S7.7.2 requires a headlamp to be installed with a mounting and aiming mechanism that allows aim inspection and adjustment, "and is accessible for those uses without removal of any vehicle parts, except for protective covers removable without the use of tools." The section is not directed to the number of covers, only the ease of removal for the specified purposes. Therefore, the use of two snap on covers is not prohibited by Standard No. 108.

Your second question is:

2) A combination of HB2-headlight (low + high beam) and auxiliary driving beam in one unit shall be equipped with only vertical adjusting screws for the driving beam. The beam pattern will be so wide that even bulbs with extreme tolerances will allow to meet all photometric requirements without horizontal adjustment. Will this be legal?

Under section S7.7.2, the aiming mechanism of a headlamp must allow for adjustment of both horizontal and vertical aim. Thus, the portion of the lamp that provides the lower and upper beam must have both horizontal and vertical aiming screws, and the headlamp would not comply with S7.7.2 if either aiming screw is lacking. For that part of the same headlamp that is a driving beam and which is therefore not regulated by Standard No. l08, the manufacturer may provide any means of adjustment it wishes, as long as it does not impair the effectiveness of the aim of the upper and lower headlamp beam. Your final question is:

3) When will the 9007 bulb be legal? Date of final rule?

According to the plans of this agency, further action on the 9007 (proposed to be known as HB5) is expected in May l990.

I hope that this responds to your questions.

Sincerely,

Stephen P. Wood Acting Chief Counsel

/ref 108 d:3/23/90

ID: nht78-4.22

DATE: 08/11/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Cars & Concepts, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

August 11, 1978

Mr. Glenn Abbott Cars & Concepts, Inc. 12500 E. Grand River Brighton, Michigan 48116

Dear Mr. Abbott:

This is in response to your letter dated June 27, 1978, asking whether fog lamps mounted to the surface of a vehicle bumper are removed prior to testing for compliance with Part 581, Bumper Standard.

Vehicles subject to the requirements of Part 581 must comply with the protective criteria of section 581.5(c) (49 CFR 581.5(c)) when tested under the conditions stated in section 581.6 (49 CFR 581.6). The test conditions make no provision for removal of fog lamps prior to testing. As was the case under Federal Motor Vehicle Safety Standard 215, Exterior Protection, the Part 581 test procedures provide for removal only of trailer hitches before testing. With the added exception of license plate brackets, excluded from the requirements of Part 581 by interpretation (42 FR 24056; May 12, 1977), other equipment (including fog lamps) attached to the bumper system prior to sale of the vehicle to its first purchaser must meet the damage limitations of the standard.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

June 27, 1978

Mr. Joseph Levin Office of the Chief Counsel N.H.T.S.A. Department of Transportation 400 7th Street S.W.

Washington, D.C. 20590

Dear Mr. Levin:

Cars & Concepts, Inc. is preparing a prototype Dodge Omni "Rally" for a 1980 model year production program. It is proposed that Chrysler Corporation ship completed vehicles to one of our facilities where we would attach certain pieces of equipment comprising the "Rally" package. The vehicles would then be shipped back to Chrysler for distribution through their normal channels. Included in the "Rally" package is a pair of Cibie C-95 white fog lamps. These would be made inoperable for highway use by means of an easily removable fuse mounted to the instrument panel. The lamps would be mounted to the top surface of the bumper (to comply with certain state regulations) and closely enough to the vehicle centerline to avoid the normal beam path of the headlights. To avoid contact with the grille when the bumper is fully compressed, it will be necessary to mount the lamps close to the bumper face placing them in potential danger of being damaged in a 5 mph pendulum test. It is our understanding that under the provisions of FMVSS #215 such items were routinely removed before testing. We are concerned that the status of accessory lighting would change under FMVSS part 581 and would like a clarification of this.

Thank you for your assistance in this matter.

Sincerely,

Glenn Abbott Design

GA/dma

cc: D. Chrysler E. Hopp D. Draper M. Pare

ID: nht68-4.20

DATE: 08/21/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Bugetta Inc.

TITLE: FMVSR INTERPRETATION

TEXT: With reference to your letter of August 14 and its enclosed specification sheet covering the Bugetta, this vehicle appears to be a "multipurpose passenger vehicle" for purpose of the Federal motor vehicle safety standards since it is constructed with features for ocasional off road use.

Your understanding of the applicability of standards to multi-purpose passenger vehicles is correct. We concur with your view that compliance with Standard No. 103 (Windshield Defrosting and Defogging) is a meaningless requirement for a vehicle with no top or windows.

BUGETTA INC.

August 14, 1968

U.S. Department of Transportation Federal Highway Administration

Attention: Robert M. O'Mahoney

Responding to letter of July 31st from Mr. David Schmeltzer, we enclose general specifications and line drawing of the vehicle which is constructed with racing components and aircraft quality fittings throughout.

The special features of this motor vehicle that are contained for occasional off-road operations are:

a. Telescopic shocks which can raise chassis approximately 18" off the ground to traverse rough terrain, water, etc.

b. Removable fiberglass body (8 pit pins) for use in mud, etc. Vehicle completely functionable with body removed.

c. Metal protective covering under entire vehicle for deflecting rocks, twigs, etc.

d. Off highway tires as standard item.

e. Roll bar for off highway and racing protection.

Safety Standards complied with: 102, 104, 106, 107, 108, 109, 111, 205, 209, 211. It was felt that the following standards did not apply primarily due to the multipurpose classification or for additional reasons given:

101 - Not applicable.

103 - Impossible requirement without top and side windows to vehicle.

105 - Not applicable.

110 - Not applicable.

112 - Not applicable.

113 - No hood, therefore not applicable.

114 - Not applicable.

201 - Not applicable.

202 - Not applicable.

203 - Not applicable.

204 - Not applicable.

206 - Not applicable. No doors.

207 - Not applicable.

208 - Not applicable.

210 - Not applicable.

301 - Not applicable.

Please review and let us know if further information is desired.

R. J. Hart

Enclosure

ID: nht90-1.5

TYPE: Interpretation-NHTSA

DATE: 01/01/90 EST

FROM: Cal Karl -- District 4700, State of Minnesota, Department of Public Safety, State Patrol

TO: All School Bus LCR II's

TITLE: Re School Bus Vandal Locks

ATTACHMT: Attached to letter dated 11-27-90 from P.J. Rice to C. Karl (A36; Std. 217); Also attached to letter dated 12-7-82 from F. Berndt to M.B. Mathieson; Also attached to letter dated 1-29-90 from C. Karl to M. Shaw (OCC 4403); Also attached to lett er dated 1-18-90 from R.E. Meadows; Also attached to letter dated 1-8-90 from R. Marion to C. Karl

TEXT:

Please be aware that some buses are appearing in the inspection process with vandal locks that do not comply with regulations.

49 CFR 571.217 provides for a lock on emergency exits. Effective 7/1/89, State Rule 3520.5010 subp 2 provides for locks on emergency doors and service door if they comply with 217.

571.217 requires the lock to disable the engine starting system if any emergency exit is locked. It further requires the presence of a person with a key or combination to activate such a mechanism.

Do not accept a bus that has a vandal lock that does not comply with this regulation. If there are buses in your area that have such locks, please make every effort to contact the operator and require that the lock be brought into compliance or removed.

Please review the language in 571.217. (Attached)

ID: nht89-2.63

TYPE: Interpretation-NHTSA

DATE: August 8, 1989

FROM: Michael F. Trentacoste -- Director, Office of Motor Carrier Standards, Federal Highway Administration

TO: Karen Finkel -- Executive Director, National School Transportation Association

TITLE: Re HCS-3

ATTACHMT: Attached to letter dated 9-29-77 from J.J. Levin, Jr. to M.B. Mathieson; Also attached to letter dated 7-5-84 from F. Berndt to R. Marion; Also attached to letter dated 3-23-90 from A.H. Brett to M.B. Mathieson; Also attached to letter dated 12 -3-90 from P.J. Rice to M.B. Mathieson (A36; Std. 217); Also attached to letter dated 3-26-90 from M.B. Mathieson to E.Z. Jones (OCC 4598); Also attached to letter dated 3-30-90 from M.B. Mathieson to M.F. Trentacoste

TEXT:

This is in response to your telephone conversation with Ms. Susan Patty of my office regarding the emergency exit requirements for buses subject to the Federal Motor Carrier Safety Regulations (FMCSRs). You asked if buses purchased as school buses, that meet National Highway Traffic Safety Administration (NHTSA) standards for school bus emergency exits, must have additional emergency exit space when used in interstate commerce and if push-out type windows are required to meet these exit requirements. W e note that NHTSA wrote to you on April 29, 1989, in response to your request for an interpretation regarding the requirements for push-out windows under Standard 217.

Title 49 C.F.R. S 393.61 establishes the window and emergency exit requirements for buses subject to the FMCSRs. Under this part, buses manufactured on or after September 1, 1973, must meet the minimum emergency requirements established under Federal Mo tor Vehicle Safety Standard 217. Buses that were manufactured before this date may either meet these requirements of Standard 217 or the requirements listed in the FMCSRs under S 393.61(b). As you know, Standard 217 establishes minimum emergency exit r equirements for school buses and different minimum emergency exit requirements for non-school buses over 10,000 Gross Vehicle Weight Rating.

Section 393.61(b)(2) says that "a bus, including a school bus, manufactured on and after September 1, 1973" (emphasis added) must conform with NHTSA's S 571.217. At the time this provision was adopted, Standard 217 applied only to other buses and it was optional for schoolbuses. The FHWA inserted the language, "including school buses," in S 393.61(b)(2) to make clear that school buses used in interstate commerce and, therefore, subject to the FMCSRs, were required to comply with the bus exit standard in Standard 217. Therefore, when a school bus is used in operations that are subject to the FMCSRs, that bus must meet the same minimum emergency exit requirements for non-school buses under S 571.217.

This interpretation is consistent with FHWA's previous interpretations on school bus operations and school bus windows. In 1975, the FHWA published its interpretations of the FMCSRs, which stated, in part, that "neither the general provisions of the Saf ety Regulations, nor the specific

provision of any part of the section of Subpart D, Part 393, contain any language which would exempt school buses from the window construction requirements" (40 Fed. Reg. 50,671, 50,689 (1975). This interpretation goes on to explain that school buses su bject to the FMCSRs, just like other buses which are subject to the FMCSRs, are given an option under S 393.61(c) to use laminated safety glass in lieu of push-out windows if the glass size is sufficient to meet the exit requirements of S 393.61 (b).

Regarding push-out windows, S 393.61(b)(3) provides that older buses must conform with the requirements of SS 393.61(b) or 571.217. Buses which are subject to S 571.217 would follow NHTSA'S interpretation on push-out windows provided to you in its April 29, 1989, letter. Buses which are subject to S 393.61(b)(1) of the FMCSRs are required to have emergency windows that are either push-out windows or that have laminated safety glass that can be pushed out in a manner similar to a push-out window. These requirements were also discussed in the 1977 FMCSRs Interpretations, under Number 4b(4) "Windshield Construction--Section 393.61." Enclosed is an excerpt from those interpretations.

I hope that this information is helpful.

ID: 1877o

Mr. Jay V. Wright
Page Avjet Corp.
2230 W. Southcross Blvd.
PO Drawer Z
San Antonio, TX 78211

Dear Mr. Wright:

This is in response to your letter of April 21, 1988, asking whether a vehicle produced by your company is a motor vehicle subject to the requirements of the Federal motor vehicle safety standards. This vehicle, referred to as a hydrant truck, consists of a chassis-cab with an equipment platform mounted on its rear. According to your letter, the platform would be equipped with accessories that allow the vehicle to be used to filter and meter aircraft fuels as fuel is pumped from airport storage tanks into aircraft.

Section 102(3) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391(3)) defines a "motor vehicle" as

any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

We have interpreted this language as follows. On the one hand, vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Agricultural equipment, such as tractors, are not motor vehicles. In addition, vehicles intended and sold solely for off-road use are not motor vehicles, even though they may be operationally capable of highway travel. Examples include airport runway vehicles.

On the other hand, vehicles that use the public roads on a necessary and recurring basis are motor vehicles. For instance, jeep-type utility vehicles are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. We have found vehicles to be motor vehicles if their on-road use is substantial, even though these vehicles' predominant intended use is off-road. Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of vehicle owners, NHTSA has found that the vehicle is a "motor vehicle." This finding was made in the case of dune buggies, regardless of the manufacturers' stated intent that the vehicles were to be used off-road only.

You stated in your letter that this vehicle is not "perceived as being moved over public roads or from airport to airport in its daily use." It appears that this vehicle is intended and sold solely for off-road use, even though the vehicle appears operationally capable of highway travel. Based on the information provided in your letter, we conclude that your company's "Hydrant Truck" does not appear to be a motor vehicle. However, we will reexamine this conclusion if we learn that, for example, the vehicle is regularly being used on the public roads.

We note that if your vehicle ever came to be regarded as a motor vehicle, there are probably few changes that would have to be made to bring it into compliance with the Federal Motor Vehicle Safety Standards (FMVSS). NHTSA encourages (but cannot require) you to make these changes. The chassis-cab used to produce the hydrant truck already has been certified by its manufacturer as an incomplete vehicle. Therefore, in order to achieve compliance, it is likely that few standards would require any changes by your company. One such standard is FMVSS 108, Lamps, reflective devices, and associated equipment. Additional changes might also be required if the weight added by the equipment platform exceeds any weight maxima specified by the chassis-cab manufacturer in making his certification.

Sincerely,

Erika Z. Jones Chief Counsel

ref:VSA d:8/ll/88