ID: 1985-01.36

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bernt Svensson -- Marketing Director, Viskafors Gummifabrik AB

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bernt Svensson Marketing Director Viskafors Gummifabrik AB Box 2059 S-515 02 Viskafors SWEDEN

This responds to your letter to Ms. Kathleen DeMeter of my staff, asking for information on how to get a new temporary spare tire size included in the tire tables following Standard No. 109 New Pneumatic Tires --Passenger Cars (49 CFR S571.109). The agency rescinded tire tables in Standard No. 109 in a final rule published at 46 FR 61473; December 17, 1981. I have enclosed a copy of that rule together with a current copy of Standard No. 109 for your records.

Section S4.4.1 requires tire manufacturers to provide a listing of the rims that may be used with each tire size it produces. Section S4.2.1(c) requires a tire's load rating to be the load rating for that size specified in a submission under S4.4.1. This may be provided by the manufacturer in a document furnished to each of the manufacturer' s dealers, to this agency, and to the public upon request. Alternatively, the manufacturer may use the data for that tire size shown in a current publication of one of the standardization organizations listed in S4.4.1(b). Your company will have to use one of these two means of complying with this requirement, instead of relying on the tire tables, as was formerly done.

The current publication of the American standardization organization (the Tire & Rim Association) shows no listing for the tire size about which you inquired. It is possible that the size is listed by one of the other standardization organizations. If not, you should either get the size listed by the standardization organization of your choosing or submit the data directly to this agency, all your dealers and the public, upon request.

Should you have any further questions on this matter, please contact Mr. Stephen Kratzke of my staff at this address.

Sincerely,

Frank Berndt Chief Counsel

Enclosures

1985-02-01 U.S. Department of Transportation M/MA2 National Highway Traffic Safety Administration 400 Seventh St. S.S. WASHINGTON, D.C. 20590 U S A

Att.: Mrs. Kathleen DeMeter

Dear Mrs. DeMeter,

From your files you may record that we are a producer of tires having the plant code VV.

We are in the process of manufacturing a spare tire for one of our clients in Sweden and would kindly ask for your advice and information as to the following points:

In the MVSS 109 regulation there are several sizes listed under the heading "T-series" 60 psi tires.

Due to various technical reasons we are considering one particular size which as far as we know is not listed namely T 125/90 R 15. (We understand that "D"-bias and "R"-radial are equal alternatives.

In connection with this we have the following questions:

Is T 125/90 "D" alt. "R" 15 now recorded in the latest edition of MVSS 109. If so could you please send us this edition showing all required data or alternatively the specific data for this tire as a complement to the MVSS 109 needed to consider and meet the USA legal requirements.

If you are not familiar with this particular size in the "T-series" range could you please advise us how we should proceed to have this tire recorded and recognized.

We would appreciate your consideration of this matter and look forward to your early response.

Very truly yours, VISKAFORS AB

Bernt Svensson Marketing Director

ID: nht90-4.3

TYPE: Interpretation-NHTSA

DATE: September 13, 1990

FROM: Danny Pugh -- Engineering Manager, Utilimaster

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12-13-90 to Danny Pugh from Paul Jackson Rice (A36; Std. 208; Part 571.3)

TEXT:

We are updating our files on FMVSS 208 in relationship to van conversions under 10,000 pounds GVW.

Is a van conversion classified as a passenger car, truck or a multi passenger vehicle?

On what date did van conversions require seatbelts, what type, and at what location?

Did van conversions ever require Type II seatbelts? At what location in the van?

Your help with these questions will be appreciated.

(Attached is a brochure from Aviator Conversions listing van conversion specifications and options. (Text and graphics omitted.))

ID: aiam2219

Dear Mr. Green: This is in response to your January 26, 1976, letter concerning th relationship between snow plows that you manufacture and the front-axle GAWR's of the vehicles on which they are mounted. Your questions and our answers are as follows:; *Question 1*. 'Somewhere I read where fire trucks are not governed b FMVSS121 or axle weight restrictions as an emergency vehicle. Is this true?'; Standard No. 121 does not apply to fire fighting vehicles manufacture before June 1, 1976. In addition, it does not apply to such a vehicle manufactured from June 1, 1976, to August 31, 1977, that either has a GAWR for any axle of 24,000 pounds or more, or has two or more front, steerable axles with a GAWR of 16,000 pounds or more for each axle. Further, the standard does not apply to any vehicle meeting any one of criteria (a) through (d), as follows:; >>>(a) An overall vehicle width of 108 inches or more, (b) An axle that has a GAWR of 29,000 pounds or more, (c) A speed attainable in two miles of not more than 33 mph, or (d) (1 A speed attainable in two miles of not more than 45 mph, and (2) An unloaded vehicle weight that is not less than 95 percent of the vehicle GVWR, and (3) No passenger-carrying capacity.; *Question 2*. 'Do you consider a snow plow an emergency piece o equipment?'; There are no exemptions in the Federal motor vehicle safety standard or regulations for 'emergency vehicles' or 'emergency equipment'.; *Question 3*. 'Would a D.O.T. compliance officer require a plow to b raised for weighing to check the GAWR?'; In determining whether a vehicle equipped with a snow plow has bee assigned an improper GAWR, the NHTSA will consider the load imposed on the axle system when the plow is in the raised position.; *Question 4*. 'The box or fold down flap I mention in letter - woul this be considered a legal method of meeting GAWR, assuming it was part of a snow plow procedure program?'; Our letter of May 9, 1974, explained that proper weight ratings depen on what you, as a vehicle alterer, know, or can reasonably be expected to know, about how the plow-equipped trucks are likely to be loaded. It stated further:; >>>A warning to the buyer not to exceed the rated cargo load or th weight ratings. . .would not be sufficient if it were reasonable to expect that the vehicles would, in practice, exceed these ratings at normal full load despite the warning.<<<; Similarly, if the volume-reducing purpose of the box or fold down fla described in your letter to county engineers is likely to be defeated (whether intentionally of (sic) accidentally), then neither would be sufficient to validate a GAWR that would otherwise be exceeded by a fully loaded axle. If, on the other hand, it is reasonable to expect that your recommended loading procedure will be followed, then it is permissible to base the GAWR on the correspondingly reduced 'full' load.; *Question 5*. 'When weighing a truck for compliance would a full loa of ballast be required even though the snow plowing procedure of governmental bodies call out a less than full load of ballast?'; The considerations discussed in no. 4 above apply here as well. *Question 6*. 'When we bid to a State where drawings and or detaile specifications of snow removal equipment are called out and no axle sizes or dump box sizes are called out are we responsible for this plow overweighing a front axle? We do not mount any equipment, we furnish equipment as specified.'; The primary responsibility for weight ratings is with the party who, b mounting the snow plow, is the vehicle alterer. If, however, your advertising or bids promote the use of the snow plow in situations where front axles are likely to be overloaded, then the plow may be considered to contain a defect relating to motor vehicle safety, which would be subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act of 1966, as amended.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 12414.ZTV

Mr. Art Maison
Purchasing Manager
Redneck, Inc.
2100 N. West By-Pass
Springfield, MO 66803

Dear Mr. Maison:

This replies to your letter of August 30, 1996, to Taylor Vinson of this Office, asking for an interpretation of the conspicuity requirements of Motor Vehicle Safety Standard No. 108.

You write that "the by-laws read that DOT-C is for the vehicles and trailers under 25,999 pounds require for that class. We would like to use these reflectors also for the DOT- C2, for the use on vehicles and trailers over 26,000 pounds."

We do not know the "by-law" to which you refer. Paragraph S5.7 of Standard No. 108 applies to all trailers of 80 or more inches overall width, and with a GVWR over 10,000 pounds. It does not distinguish between those over and under 26,000 pounds. Therefore, a trailer with a GVWR of 26,000 pounds must meet the same requirements of paragraph S5.7 as a trailer with a GVWR of 10,001 pounds.

We understand that you have discussed your problem with Pat Boyd, one of this agency's rulemaking engineers, and that your questions are: "What is the difference between DOT-C and DOT C-2" and "Does a reflex reflector have to be 2 inches wide, like reflective tape?"

Paragraph S5.7 permits a manufacturer to choose either reflex reflectors or reflective tape as the way to conform to the conspicuity requirements of Standard No. 108. "DOT-C" is the marking required for reflex reflectors, and is the reflector manufacturer's certification that the reflectors meet Standard No. 108 (Paragraph S5.7.2.3). "DOT- C2" is the marking required for reflective tape which has a width of not less than 50 mm (2 inches) and is the reflective tape manufacturer's certification that the tape meets Standard No. 108 (Paragraphs S5.7.1.3(d) and S5.7.1.5). Standard No. 108 does not require that reflex reflectors have a minimum width. Reflex reflectors are rated by the total light return per reflector, but reflective tape is rated by the light return per unit area. Standard No. 108 requires that one reflex reflector, meeting the DOT-C specification, have the same total light return as 100 mm of reflective tape meeting the DOT-C2 specification. We have seen reflex reflector bars 300 mm long certified to meet the DOT-C specification for each 100 mm segment. Standard No. 108 permits the use of these products even though they are only about 1 inch wide because they provide the same photometric performance as 300 mm of DOT -C2 reflective tape. I enclose a copy of the recent final rule which extended these requirements to truck tractors, and have circled language on p. 41357 which mentions this point.

I hope that this is responsive to your request. If you have any further questions, you may call Taylor Vinson at 202-366-5263.

Sincerely,

John Womack

Acting Chief Counsel

Enclosure

ref:108

d:9/25/96

ID: nht76-1.28

DATE: 08/06/76

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Hon. John J. LaFalce - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your correspondence on behalf of Mr. George J. Ciancio, concerning the tires on his 1975 Dodge Van B-100. Prior to responding, this office contacted Mr. Ciancio for additional information.

From the correspondence you submitted to this Administration, Mr. Ciancio did not appear to receive satisfactory responses to the questions he submitted to the Chrysler Corporation concerning the tire problems he was experiencing. We offer the following responses for his consideration:

Question 1 - Stamped on the sidewalls of the original tire the rating is 1400 pounds. Is this maximum load?

Response - Yes. The maximum load rating for an E7815 B passenger car type tire is 1400 pounds. This rating is only applicable when this tire is used for passenger car service. For a van of the type used by Mr. Ciancio, a service factor is applied for "truck service" and the maximum load becomes 1270 pounds.

Question 2 - My registration shows the van weight at 4434 pounds. What is the laden weight of the B-100 van?

Response - Mr. Ciancio was contacted on this point. Our data indicates that the Dodge B-100 van should weigh approximately 3600 pounds depending on the installed equipment. As the Gross Vehicle Weight Rating (GVWR) is 4600 pounds, the approximate laden weight would be about 1000 pounds as indicated by Chrysler. If in fact, the van does weigh 4434 pounds empty, then the laden weight cannot be over 166 pounds, which of course, cannot be correct.

Question 3 - Do I read correctly that my total tire weight allows 5400 pounds, which includes van and load?

Response - No. From page 3 of your Owners Manual, you will note, "The GVW rating of your truck as manufactured is shown on the Safety Certification Label. The GVW rating is the total permissible weight of your truck including driver, passengers, body, and payload." As the GVWR of the B-100 van is 4600 pounds, 4600 pounds is the maximum load.

Question 4 - The axle capacity in the manual front and rear is shown as 2700 pounds. Does this mean with loaded weight?

Response - No. The axle capacity of 2700 pounds is the rating determined by the vehicle manufacturer as the maximum load that should be applied to that individual axle - it does not mean that both axles can take the design capacity for a total of 5400 pounds. Again, the B-100 van is limited to 4600 pounds GVW. Vehicle load on each axle is further limited by the suspension's spring and wheel ratings which reduce actual load carrying capacity to GAWR valves of 2480 front and 2340 rear. These figures indicate the importance of proper load distribution in the vehicle.

Question 5 - Is it true if I increase my tire size from E78-15B to G78-15B, would it make any difference in the load I could carry without jeopardizing the axle weight capacity?

Response - No. By changing the tires on the van from E ratings to G ratings would not change the GVWR of 4600 pounds. The van is still limited to a GVWR of 4600 pounds.

We hope that the responses to these questions will answer some of the concerns of Mr. Ciancio.

ID: aiam5002

"Dear Senator Gramm: Thank you for your letter on behalf of you constituent, Mr. Frank Sonzala, Senior Vice President of International Transquip Industries (ITI), regarding Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems. ITI is a manufacturer of air brake systems and is apparently having difficulty selling its product to vehicle manufacturers because of a compliance issue related to Standard No. 121. The National Highway Traffic Safety Administration's Chief Counsel, Paul Jackson Rice, reviewed Mr. Sonzala's concerns, and I am pleased to provide you the following information. By way of background information, NHTSA issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, the Safety Act requires manufacturers to certify that their vehicles or equipment comply with applicable safety standards. Standard No. 121 specifies braking requirements for vehicles equipped with air brake systems. The purpose of the standard is to ensure safe braking performance under normal and emergency conditions. The standard applies only to motor vehicles and not to motor vehicle equipment. Therefore, vehicle manufacturers are responsible for ensuring compliance with the standard, and not brake equipment manufacturers such as ITI. The dispute between ITI and the vehicle manufacturers (ITI uses the term 'original equipment manufacturers') relates to the standard's parking brake requirements. The specific requirement at issue, set forth at S5.6 of Standard No. 121, requires a vehicle's parking brake to meet certain grade holding requirements (or other equivalent requirements) with 'any single leakage-type failure' of certain parts, including service brake chamber diaphragms. The purpose of this requirement is to ensure that a driver can safely park his or her vehicle in the event of a leakage-type failure in the service brake system. Leakage- type failures include such things as ruptured or severed brake hoses and torn diaphragms. Since these types of failures are relatively common in air brake systems, NHTSA believes that it is important that drivers be able to safely secure heavy trucks and other vehicles with such failures, until the vehicles can be repaired. For the purpose of determining whether a vehicle can meet Standard No. 121's grade holding requirements with one particular leakage-type failure, a failed diaphragm, ITI would like the standard to be interpreted to cover only a very limited and specific type of failure, i.e., a hole 1/8 inch in size located in a particular place. ITI states that the vehicle manufacturers generally have a broader view of what constitutes a failed diaphragm, i.e., they believe that failures include holes larger than 1/8 inch. ITI argues that Standard No. 121 is ambiguous in this area and requests NHTSA to issue an interpretation supporting its position. After consulting with NHTSA's Chief Counsel, we can state that the vehicle manufacturers are correct in their understanding that a failed diaphragm is not limited to a diaphragm with a 1/8 inch hole. Therefore, if a vehicle cannot pass Standard No. 121's grade holding test with a larger hole in a failed diaphragm, the vehicle manufacturer cannot certify that the vehicle complies with the standard. Further, we disagree with ITI's contention that Standard No. 121 is ambiguous as to what constitutes a failed diaphragm. As indicated above, Standard No. 121 specifies that the grade holding requirements must be met with any single leakage-type failure of certain parts, including a failed diaphragm. The usage of the term 'any,' when used in connection with a set of items, is specifically defined at 49 CFR 571.4 as meaning the totality of that set of items, any one of which may be selected by the Administration for testing. Thus, a vehicle must meet the grade holding requirements regardless of the extent of the failure selected by NHTSA for testing. We note that leakage-type failures of many types and sizes can occur in vehicle brake systems. NHTSA intentionally did not limit the size or location of such failures in developing this requirement to ensure that a vehicle has adequate grade holding performance regardless of the specific nature of such a failure. ITI also asked whether other broken components, such as heavy parking springs, brake shoes, linings, and drums should be part of Standard No. 121's test requirements, since diaphragms are tested when torn. Although NHTSA's brake standards do not have any express test requirements for broken parking springs, brake shoes, linings or drums, those standards include a number of requirements to ensure adequate braking performance in the event of various failures in a vehicle's brake system. We hope that this information is helpful. Sincerely, Frederick H. Grubbe Enclosure: Constituents Correspondence cc: Washington Office";

ID: aiam5003

"Dear Senator Gramm: Thank you for your letter on behalf of you constituent, Mr. Frank Sonzala, Senior Vice President of International Transquip Industries (ITI), regarding Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems. ITI is a manufacturer of air brake systems and is apparently having difficulty selling its product to vehicle manufacturers because of a compliance issue related to Standard No. 121. The National Highway Traffic Safety Administration's Chief Counsel, Paul Jackson Rice, reviewed Mr. Sonzala's concerns, and I am pleased to provide you the following information. By way of background information, NHTSA issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, the Safety Act requires manufacturers to certify that their vehicles or equipment comply with applicable safety standards. Standard No. 121 specifies braking requirements for vehicles equipped with air brake systems. The purpose of the standard is to ensure safe braking performance under normal and emergency conditions. The standard applies only to motor vehicles and not to motor vehicle equipment. Therefore, vehicle manufacturers are responsible for ensuring compliance with the standard, and not brake equipment manufacturers such as ITI. The dispute between ITI and the vehicle manufacturers (ITI uses the term 'original equipment manufacturers') relates to the standard's parking brake requirements. The specific requirement at issue, set forth at S5.6 of Standard No. 121, requires a vehicle's parking brake to meet certain grade holding requirements (or other equivalent requirements) with 'any single leakage-type failure' of certain parts, including service brake chamber diaphragms. The purpose of this requirement is to ensure that a driver can safely park his or her vehicle in the event of a leakage-type failure in the service brake system. Leakage-type failures include such things as ruptured or severed brake hoses and torn diaphragms. Since these types of failures are relatively common in air brake systems, NHTSA believes that it is important that drivers be able to safely secure heavy trucks and other vehicles with such failures, until the vehicles can be repaired. For the purpose of determining whether a vehicle can meet Standard No. 121's grade holding requirements with one particular leakage-type failure, a failed diaphragm, ITI would like the standard to be interpreted to cover only a very limited and specific type of failure, i.e., a hole 1/8 inch in size located in a particular place. ITI states that the vehicle manufacturers generally have a broader view of what constitutes a failed diaphragm, i.e., they believe that failures include holes larger than 1/8 inch. ITI argues that Standard No. 121 is ambiguous in this area and requests NHTSA to issue an interpretation supporting its position. After consulting with NHTSA's Chief Counsel, we can state that the vehicle manufacturers are correct in their understanding that a failed diaphragm is not limited to a diaphragm with a 1/8 inch hole. Therefore, if a vehicle cannot pass Standard No. 121's grade holding test with a larger hole in a failed diaphragm, the vehicle manufacturer cannot certify that the vehicle complies with the standard. Further, we disagree with ITI's contention that Standard No. 121 is ambiguous as to what constitutes a failed diaphragm. As indicated above, Standard No. 121 specifies that the grade holding requirements must be met with any single leakage-type failure of certain parts, including a failed diaphragm. The usage of the term 'any,' when used in connection with a set of items, is specifically defined at 49 CFR 571.4 as meaning the totality of that set of items, any one of which may be selected by the Administration for testing. Thus, a vehicle must meet the grade holding requirements regardless of the extent of the failure selected by NHTSA for testing. We note that leakage-type failures of many types and sizes can occur in vehicle brake systems. NHTSA intentionally did not limit the size or location of such failures in developing this requirement to ensure that a vehicle has adequate grade holding performance regardless of the specific nature of such a failure. ITI also asked whether other broken components, such as heavy parking springs, brake shoes, linings, and drums should be part of Standard No. 121's test requirements, since diaphragms are tested when torn. Although NHTSA's brake standards do not have any express test requirements for broken parking springs, brake shoes, linings or drums, those standards include a number of requirements to ensure adequate braking performance in the event of various failures in a vehicle's brake system. We hope that this information is helpful. Sincerely, Frederick H. Grubbe Enclosure: Constituents Correspondence cc: Washington Office";

ID: aiam4861

"Dear Mr. Haywood: This responds to your letter of March 20, 1991 wit respect to 'the sale of a very limited number of specially built cars in the U.S.' Components would be manufactured by Porsche. The chassis would be 'a carbon fiber 962 racing tub' with a hand built body. The car could be imported either as an assembled vehicle or as a kit and assembled here. You have asked for information regarding 'low volume manufacturers exemptions from certain DOT regulations, emissions, passive restraints, bumper height, and all other pertinent information regarding manufacturing and sale of vehicles in the U.S.' You have not enclosed a photo of the car but your remark that the chassis is a 'racing tub' raises the possibility that the vehicle may be intended for racing purposes. Single-seat vehicles imported for competition on closed circuit courses and not used on the public roads are generally not 'motor vehicles' under the National Traffic and Motor Vehicle Safety Act, and no regulations apply to them. If you wish to pursue this possibility further, please send us more information on the vehicle. Assuming that the car is subject to the Safety Act, its manufacturer is eligible to apply for a temporary exemption from one or more of the Federal motor vehicle safety standards on several grounds. Exemptions of up to three years may be provided a manufacturer whose total motor vehicle production was 10,000 units or less in the year preceding the filing of its petition. Alternatively, exemptions of up to two years may be provided covering up to 2,500 vehicles per year if the manufacturer-petitioner can demonstrate that the exemption would facilitate the field evaluation of innovative safety features or low-emission vehicles, or if, in the absence of an exemption, the manufacturer would be prevented from selling a motor vehicle whose overall level of safety is at least equivalent to that of a vehicle complying with all the safety standards. However, the exemption authority extends only to the safety standards. The bumper height standard was issued under the authority of the Motor Vehicle Information and Cost Savings Act which contains no exemption provisions. The emission standards are issued by the Environmental Protection Agency, which is not part of the Department of Transportation, and you will have to contact them as to their requirements. If the intent is to import a fully assembled motor vehicle into the United States, at the time of entry it will have to bear the certification of its manufacturer that it complies with all applicable Federal motor vehicle safety, bumper, and theft prevention standards (the certification label must also list the standards from which exemptions may have been provided). If the intent is to ship the vehicle in a disassembled state for assembly by the purchaser or manufacturer's agent in the United States, and if the kit contains l00% of the parts necessary for assembly, we regard the foreign supplier as the 'manufacturer', responsible for ensuring compliance with all Federal requirements, including provision of certification. I enclose an information sheet with respect to the regulations that we administer, and will be pleased to answer any further questions you may have. If you prefer to telephone, Taylor Vinson of this Office will be able to help you (202-366-5263). Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam1358

Dear Mr. Sage: This is in reply to your letter of December 20, 1973, concerning th placement of rear identification lamps on the header of Fruehauf trailers.; I enclose a copy of a recent exhange (sic) of correspondence betwee Fruehauf and this agency on this question which I believe is in point. It is our view that if a lamp is available which may be installed in a narrow header area, the upper location is 'practicable' even though the lamps may not be the one specified by the vehicle's purchaser.; Yours truly, Richard By. Dyson, Assistant Chief Counsel

ID: aiam3969

Dear Mr. Tuel: This responds to your letter of February 4, 1985, inquiring about th applicability of 49 CFR Part 566, *Manufacturer Identification*, and 49 CFR Part 573, *Defect and Noncompliance Reports*, to your client, Stockton Dodge. I regret the delay in our response.; You asked whether Stockton Dodge, as a vehicle alterer, would b considered a manufacturer under the statutory definition of 'manufacturer' in the National Traffic and Motor Vehicle Safety Act as amended, 15 U.S.C. 1391, *et seq.* (the Act). Based on the information given, the answer is yes.; You state that Stockton Dodge purchases previously certified Dodge van from Chrysler Corporation and converts them into school buses which are intended to be sold directly to school districts. The modifications made by your client include adding seats, strengthening the roof structure, and adding required warning lights and emergency equipment. You state that Stockton Dodge will certify the altered vehicles according to the requirements of 49 CFR Part 567.7, as complying with all Federal motor vehicle safety standards applicable to school buses.; Stockton Dodge sent a letter to the Administrator, dated March 7, 1985 stating that, beginning February 15, 1985, its school bus division would become a final-stage manufacturer. Stockton Dodge stated that they would purchase Dodge B350 vans from Chrysler Corporation which school bus options and would add equipment to alter these vehicles to Type 2 school buses, weighing under 10,000 GVWR. Under our regulations, your client is not considered a final-stage manufacturer because the definition of final-stage manufacturer in 49 CFR Part 568 applies to a person who finishes an incomplete vehicle.; This agency considers Stockton Dodge an alterer of previously certifie motor vehicles, as indicated in your letter, who must comply with the certification requirements of 49 CFR 567.7. Your client's alterations change the vehicle type from a multipurpose van to a school bus and affect components necessary for compliance with safety standards. For these reasons, Stockton Dodge is a manufacturer within the meaning of the Act, as stated above. Stockton Dodge's letter dated March 7, 1985, contains the information required to be submitted under 49 CFR Part 566, *Manufacturer Identification*. The agency will consider this letter as the manufacturer identification for Stockton Dodge as an alterer.; This agency has also determined that an alterer is considered manufacturer for the purposes of notification and recall for defects or noncompliance under the Act and is subject to the requirements of 49 CFR Part 573, *Defect and Noncompliance Reports*.; Please note that, under paragraph S4.1 of Standard No. 115, *Vehicl Identification Number--Basic Requirements* (VIN), Stockton Dodge, as the alterer, should use the VIN assigned by Chrysler Corporation, the original manufacturer of the vehicles.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel