Interpretation ID: aiam0115
Assistant Sales Manager
Blaw-Knox Company
Mattoon
IL 61938;
Dear Mr. Wright: Thank you for your letter of July 11, 1968, in which you provide certification information.; With reference to the Service Bulletin dated '4-10-68' in the secon paragraph you state that mixer units mounted at the factory will display a 'Certification of Compliance' plate. Blaw-Knox, when it is the party mounting a mixer to a chassis-cab, must insure compliance with Federal Standard No. 108 in effect on the date of manufacture of the chassis-cab, but it is required to furnish certification only when the completed vehicle is being shipped to a dealer or distributor for sale to the ultimate purchaser. No certification is required when such a purchaser brings a chassis- cab to the factory for mixer installation. With reference to the third paragraph, it is not necessary for you to supply a certification plate for mixer equipment which is shipped from the factory for mounting elsewhere. Compliance with Federal Standard No. 108 is the responsibility of the party who mounts the mixer to the chassis-cab.; Since the chassis-cab manufacturer will have provided serial numbe information sufficient to determine the requirements of Standard No. 108 in effect on the date of manufacture of the chassis-cab, it is not necessary to include the mixer serial number on the certification plate. We would suggest that you may comply with the certification requirements of Section 114 of the Act when you deliver the completed vehicle to a dealer or distributor for sale to the ultimate purchaser by wording your certification as follows:; >>>'Blaw-Knox Company certifies to the distributor or dealer that i has mounted the mixer unit to the chassis and that the completed vehicle conforms with Federal Motor Vehicle Safety Standard No. 108.'<<<; A notice of proposed rule making which will result in more specifi requirements with reference to certification will be published in the Federal Register in the near future. A copy of the notice will be sent Blaw-Knox.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service;