ID: nht72-5.34

DATE: 03/21/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1972, concerning the application of the Certification regulations (49 CFR Part 567) to certain vehicles and components.

You describe a device, called a "converter gear", which is used to convert a semi-trailer into a trailer, and ask whether this unit is considered to be a trailer which must be certified. You also ask whether all lamps and reflectors specified for trailers are required. We believe this device to be a trailer, as it appears from your description that it is a "trailer converter dolly" under the Motor Vehicle Safety Standards (49 CFR @ 571.3). Trailer converter dollies are specifically exempt from the requirements of Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment," and are consequently not required to meet the lighting requirements applicable to other trailers. In addition, there are presently no other motor vehicle safety standards applicable to trailers and consequently, trailer converter dollies need not be certified. This will no longer be the case, however, after the effective date of Standard No. 121, "Air Brake Systems." Trailer converter dollies manufactured on or after that standard's effective date will be required to comply with its requirements, and to be certified in accordance with Part 567.

You also ask how manufacturers are to determine the GVWR for semi-trailers, and whether such a figure can be based solely on the semi-trailer's axle or axles. The GVWR of a semi-trailer should not be based on the vehicle's axles. The definition of GVWR calls for the weight of a fully loaded vehicle, and normally the capacity of a semi-trailer is greater than that of its rear axles.

You describe another device, a "Jo-Dog" or detachable tag axle to be attached to a truck tractor, asking whether this unit is a "trailer" which must be certified and whether the use of such a device would alter the truck tractor to the extent that an altered certification label is required. It appears from your description of this device that it is also a "trailer converter dolly." As in the case of the "converter gear" described above, certification by the manufacturer (at the present time) is not required. Moreover, we would not consider the use of such a device to be "manufacturing" within the National Traffic and Motor Vehicle Safety Act, and no certification of any kind by a user (as distinguished from a manufacturer) would be required.

Finally you describe additional devices, a "drom," and an auxiliary cargo-carrying platform, both of which can be added to truck tractors between the cab and the fifth wheel. You ask whether the installation of such devices would constitute re-manufacturing of the vehicle and if additional certification is required when compliance to a standard is not altered.

We would consider the addition of such components to a new vehicle to be manufacturing under the National Traffic and Motor Vehicle Safety Act, and certification by the vehicle manufacturer would be required regardless of whether compliance of the vehicle to any standard is affected.

We are pleased to be of assistance.

ID: nht72-5.35

DATE: 09/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 31 and September 13, 1972, concerning certification of trailers and the addition of snow plows to completed vehicles.

In your letter of August 31 you asked how a final-stage manufacturer, or re-manufacturer, should verify a vehicle when as part of the work he performed he utilizes a used component. It is permissible for the manufacturer to certify the vehicle as if the component in question were new. You also ask for the status of a person who sells a trailer with what appears to be a kit by which the purchaser installs a section of the floor. We agree with your conclusion, assuming the floor is not "readily attachable", that such a manufacturer would be an incomplete vehicle manufacturer under Parts 567 and 568. He would consequently be required to furnish the purchaser with an "incomplete vehicle document" in accordance with Part 568, on which the purchaser can rely in completing and certifying the vehicle.

You are correct in the conclusion of your second letter that a person adding a snow plow to a completed vehicle (of which he is not the manufacturer) need not certify the vehicle, even if he must add auxiliary lights pursuant to Motor Vehicle Safety Standard No. 106. Such a person is not a complete or incomplete vehicle manufacturer, and need not report production figures pursuant to Part 573, Defect Reports.

ID: nht72-5.36

DATE: 04/11/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Edward L. Adams

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 17, 1972, in which you ask for information on safety specifications as they would apply to travel trailers.

All trailers manufactured for use on the public roads are required to meet applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the date of manufacture. Part 567 of Title 49 of the Code of Federal Regulations requires that a certification label be attached to the left front of the trailer. A specific conformity statement is required, among other things, on the label. A copy of the regulation is enclosed.

We do not have information at this time that would add to the article in the St. Louis Post Dispatch.

Thank you for your interest in the program of the National Highway Traffic Safety Administration.

ID: nht72-5.37

DATE: 06/21/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: A.B. Chance Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 31 to Mr. Schneider asking about the motor vehicle safety standards and regulations applicable to the crewcabs that you manufacture and mount on truck chassis "with and without hydraulic digger/derric equipment.

Based upon the data you submitted, your vehicle should be identified (Illegible Line) to Federal standards applicable to trucks. With respect to the crewcabs, these include standards No. 205 Glazing Materials, Standard No, 206 (Illegible Words) Retention (Illegible Word) Standard No. 207, (Illegible Line) No. 209. Seat Belt Assemblies, Standard No. 210, Seat Belt Assembly Anchorages, (Illegible Word) Standard No. (Illegible Words) Flammability (Illegible Words) materials. (Illegible Words) manufacturer, you are governed by the regulations on certification (Part 567) and vehicles manufactured in two or more stages (Part 568). There are no requirments for rollbar, ventiletion, or "impact stability."

You can find those standards and regulations at Title 49. Code of Federal Regulations, Part 571, or you may obtain a copy of all standards and regulations, updated regularly by writing the Superintendent of Documents. U.S. Government Minting Office, Washington D.C. 20402, and enclosing a check for $ 6.00. The Truck Body and Equipment Association also has a good service in the area.

ID: nht72-5.38

DATE: 03/20/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robert Waggoner

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1972, requesting information on "a new law effective January 1, 1972, that makes it mandatory that manufacturers of truck bodies and those repairing such items must now certify their product."

The National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) has required since January 1, 1968, that manufacturers of motor vehicles and motor vehicle equipment certify that the products they manufacture comply with all applicable Federal motor vehicle safety standards (49 CFR 571.101 et seq.). The "new law" to which you refer is actually regulations issued pursuant to Section 114 of the Act (15 U.S.C. 1403) which amended existing regulations specifying the method by which manufacturers are to certify compliance. These regulations are the Certification regulations (49 CFR Part 567) and the regulations governing "Vehicles Manufactured in Two or More Stages" (49 CFR Part 568). I have enclosed copies of both for your information.

These regulations apply to manufacturers and distributors of motor vehicles as defined in the regulations. They only apply to manufacturers of truck bodies if such manufacturers install the truck bodies on chassis, thus completing the vehicles. The regulations do not apply to one who only repairs truck bodies.

ID: nht72-5.39

DATE: 01/31/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: (Illegible Words)

ID: nht72-5.4

DATE: 11/22/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Motor Coach Industries Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 23, 1972, in which you ask whether it is permissible under the Certification regulations for you to list alternative tire sizes and gross axle weight ratings on certification labels for vehicles which you sell without tires, but on which you apparently install them before delivery. You indicate that the tires are supplied by the customer, which he either owns, leases, or purchases from you.

Under the Certification regulation, you may if you wish list alternative tire sizes, and alternative gross vehicle or gross axle weight ratings, as you described in your letter. If you install the tires, regardless of whether they are owned by the vehicle purchaser, leased, or purchased from you, the tire you install should be one of the alternative sizes listed on the certification label.

ID: nht72-5.40

DATE: 03/30/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 16, 1972, forwarding to us a draft of a TTMA Recommended Practice concerning GAWR and GVWR that you have developed as a guide for the truck trailer industry. You ask whether the draft is consistent with the applicable regulations (49 CFR Parts 567, 568).

The draft which you submitted is consistent with the regulations although it is much more specific than the regulations and represents just one method of achieving compliance. We appreciate your efforts in making the substance of the regulations available to this large segment of the industry.

ID: nht72-5.41

DATE: 07/19/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Stutz Motor Car of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 21, 1972. As I understand it, your company purchases Pontiac Grand Prix models for conversion into vehicles bearing the Stutz nameplate. Your converter, however, has a number of vehicles in stock, the majority of which will not be converted until after September 1, 1972. You ask, in effect, that we require compliance only with those Federal standards in effect on the date of manufacture of the original Pontiac Grand Prix, and that we do not require compliance with standards which may have come into effect after that time and before completion of the State conversion.

The information contained in your letter indicates that the changes you make to the Grand Prix are confined to cosmetic changes such as alteration of the exterior sheet metal, reupholstering the interior, and replacement of the back light with glazing conforming to Standard No. 205. If the converted Grand Prix conforms to those Federal motor vehicle safety standards for which temporary exemptions was granted State (Standards Nos. 104, 201, 205, 210 and 212), we will consider it permissible for General Motors to continue to be the "manufacturer" of the vehicle for certification purposes. In that case, the date of manufacture is considered to be the date of completion by General Motors, and the original certification label should be retained on the car when converted.

The vehicle must nevertheless conform at the time of sale to all safety standards and other regulations (for example, 49 CFR Part 575, Consumer Information) that are applicable on its date of manufacture.

ID: nht72-5.42

DATE: 03/01/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Avis M. Hicks

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 14, 1971, in which you ask certain questions relating to "Gross Vehicle Weight Rating" (GVWR) as it would apply to our regulations, 49 CFR 567 and 568. Our requirement that certain weight ratings be applied to a label by vehicle manufacturers is a regulation and not a Federal motor vehicle safety standard.

Gross vehicle weight rating as defined in @ 568 of the regulations "means the value specified by the manufacturer as the loaded weight of a single vehicle." This was further clarified in the Federal Register on October 8, 1971, 36 (Illegible Words) "To preclude the possibility of understating a vehicle's GVWR, however, the certification regulation is herewith amended to provide that the stated GVWR shall not be less than the sum of unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity." Unloaded vehicle weight has been defined as ". . . the weight of a vehicle with maximum capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants," 36 FR 2511.

From the standpoint of the regulation itself, the only other limit on GVWR would be that it should not be more than the sum of the gross axle weight ratings (although it may be less), since otherwise the vehicle would obviously be supplied with axle systems inadequate for its carrying capacity.

Good engineering practice would dictate that weight ratings be based on the weakest component in the system regardless of what it, the weakest component, might be. Of course, weight distribution is one of the factors that must be considered in making these calculations. In the example you have cited, if a manufacturer supplied a rear axle on his vehicle with a stated axle weight rating of 13,000 pounds with tires on the axle having a sum total rating of something less he would be overstating the GVWR of a particular axle on his certification label. GVWR's should not be greater than the total tire capacity or as stated before the sum of the gross axle weight ratings.

If you have further questions, I will be pleased to answer them.